Brigham City v. Stuart
Annotate this Case
547 U.S. 398 (2006)
OCTOBER TERM, 2005
BRIGHAM CITY V. STUART
SUPREME COURT OF THE UNITED STATES
BRIGHAM CITY, UTAH v. STUART et al.
certiorari to the supreme court of utah
No. 05–502. Argued April 24, 2006—Decided May 22, 2006
Responding to a 3 a.m. call about a loud party, police arrived at the house in question, heard shouting inside, proceeded down the driveway, and saw two juveniles drinking beer in the backyard. Entering the yard, they saw through a screen door and windows an altercation in the kitchen between four adults and a juvenile, who punched one of the adults, causing him to spit blood in a sink. An officer opened the screen door and announced the officers’ presence. Unnoticed amid the tumult, the officer entered the kitchen and again cried out, whereupon the altercation gradually subsided. The officers arrested respondents and charged them with contributing to the delinquency of a minor and related offenses. The trial court granted their motion to suppress all evidence obtained after the officers entered the home on the ground that the warrantless entry violated the Fourth Amendment, and the Utah Court of Appeals affirmed. Affirming, the State Supreme Court held that the injury caused by the juvenile’s punch was insufficient to trigger the “emergency aid doctrine” because it did not give rise to an objectively reasonable belief that an unconscious, semiconscious, or missing person feared injured or dead was in the home. Furthermore, the court suggested the doctrine was inapplicable because the officers had not sought to assist the injured adult but had acted exclusively in a law enforcement capacity. The court also held that the entry did not fall within the exigent circumstances exception to the warrant requirement.
Held: Police may enter a home without a warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury.
Because the Fourth Amendment’s ultimate touchstone is “reasonableness,” the warrant requirement is subject to certain exceptions. For example, one exigency obviating the requirement is the need to render emergency assistance to occupants of private property who are seriously injured or threatened with such injury. Mincey v. Arizona, 437 U. S. 385, 392. This Court has repeatedly rejected respondents’ contention that, in assessing the reasonableness of an entry, consideration should be given to the subjective motivations of individual officers. Because the officers’ subjective motivation is irrelevant, Bond v. United States, 529 U. S. 334, 338, n. 2, it does not matter here whether they entered the kitchen to arrest respondents and gather evidence or to assist the injured and prevent further violence. Indianapolis v. Edmond, 531 U. S. 32, 46, and Florida v. Wells, 495 U. S. 1, 4, distinguished. Relying on this Court’s holding in Welsh v. Wisconsin, 466 U. S. 740, 753, that “an important factor to be considered when determining whether any exigency exists is the gravity of the underlying offense for which the arrest is being made,” respondents further contend that their conduct was not serious enough to justify the officers’ intrusion into the home. This contention is misplaced. In Welsh, the “only potential emergency” confronting the officers was the need to preserve evidence of the suspect’s blood-alcohol level, an exigency the Court held insufficient under the circumstances to justify a warrantless entry into the suspect’s home. Ibid. Here, the officers were confronted with ongoing violence occurring within the home, a situation Welsh did not address.
The officers’ entry here was plainly reasonable under the circumstances. Given the tumult at the house when they arrived, it was obvious that knocking on the front door would have been futile. Moreover, in light of the fracas they observed in the kitchen, the officers had an objectively reasonable basis for believing both that the injured adult might need help and that the violence was just beginning. Nothing in the Fourth Amendment required them to wait until another blow rendered someone unconscious, semiconscious, or worse before entering. The manner of their entry was also reasonable, since nobody heard the first announcement of their presence, and it was only after the announcing officer stepped into the kitchen and announced himself again that the tumult subsided. That announcement was at least equivalent to a knock on the screen door and, under the circumstances, there was no violation of the Fourth Amendment’s knock-and-announce rule. Furthermore, once the announcement was made, the officers were free to enter; it would serve no purpose to make them stand dumbly at the door awaiting a response while those within brawled on, oblivious to their presence. Pp. 3–7.
2005 UT 13, 122 P. 3d 506, reversed and remanded.
Roberts, C. J., delivered the opinion for a unanimous Court. Stevens, J., filed a concurring opinion.