Brigham City v. Stuart

547 U.S. 398 (2006)

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Nature of the Case

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Facts

At about 3 a.m., four police officers responded to a call regarding a loud party at a residence. They heard shouting from inside and proceeded down the driveway to investigate. They observed two juveniles drinking beer in the backyard. They entered the backyard and saw--through a screen door and windows--an altercation taking place in the kitchen of the home. Four adults were attempting, with some difficulty, to restrain a juvenile. The juvenile eventually 'broke free, swung a fist and struck one of the adults in the face.' The victim of the blow was spitting blood into a nearby sink. The other adults continued to try to restrain the juvenile, pressing him up against a refrigerator with such force that the refrigerator began moving across the floor. An officer opened the screen door and announced their presence. Nobody took notice. The officer entered the kitchen and again cried out, and as the occupants slowly became aware that the police were on the scene, the altercation ceased. The officers subsequently arrested Stuart (Ds). Ds filed a motion to suppress all evidence obtained after the officers entered the home, arguing that the warrantless entry violated the Fourth Amendment. The court granted the motion, and the Utah Court of Appeals affirmed. The Supreme Court of Utah held that the injury caused by the juvenile's punch was insufficient to trigger the so-called 'emergency aid doctrine' because it did not give rise to an ' objectively reasonable belief that an unconscious, semi-conscious, or missing person feared injured or dead [was] in the home.' The court suggested that the doctrine was inapplicable because the officers had not sought to assist the injured adult, but instead had acted 'exclusively in their law enforcement capacity.' It held that the entry did not fall within the exigent circumstances exception to the warrant requirement. The Supreme Court granted certiorari in light of differences among state courts and the Courts of Appeals concerning the appropriate Fourth Amendment standard governing warrantless entry by law enforcement in an emergency situation.