holding that, once an arrest warrant has been issued, it is constitutionally reasonable to require the suspect to open the doors of his home to police officers because “for Fourth Amendment purposes, an arrest warrant founded on probable cause implicitly carries with it the limited authority to enter a dwelling in which the suspect lives when there is reason to believe the suspect is within”
How later courts described this case
- holding that, once an arrest warrant has been issued, it is constitutionally reasonable to require the suspect to open the doors of his home to police officers because “for Fourth Amendment purposes, an arrest warrant founded on probable cause implicitly carries with it the limited authority to enter a dwelling in which the suspect lives when there is reason to believe the suspect is within”
- holding that a New York statute “authoriz[ing] police officers to enter a private residence without a war- rant and with force, if necessary, to make a routine felony Cite as: 576 U. S. ____ (2015) 7 Opinion of the Court arrest” was “not consistent with the Fourth Amendment”
- recognizing "long-settled premise that absent exigent circumstances, a warrantless entry to search for weapons or contraband is unconstitutional even when a felony has been committed and there is probable cause to believe that incriminating evidence will be found within"
- holding that “the Fourth Amendment to the United States Constitution, made applicable to the States by the Fourteenth Amendment prohibits the police from making a warrantless and nonconsensual entry into a suspect’s home in order to make a routine felony arrest.”
Written by the judges who cited it.
Later courts went against this
Disagreed with by Alexander ex rel. Estate of Quade v. City & County of San Francisco, 29 F.3d 1355 (1994)
We also disagree with Judge Trott's argument that because the "chief evil” Payton guards against is entry into the home, and because the officers had a lawful basis for entry in the form of the forcible entry warrant, there was no Fourth Amendment violation.
Limited by State v. Hatchie, 161 Wash. 2d 390 (2007)
While the Supreme Court limited its holding in Payton to felony arrest warrants — as per the facts before it — it expanded its analysis to misdemeanor warrants in Welsh v. Wisconsin, 466 U.S. 740, 750, 104 S. Ct. 2091, 80 L. Ed. 2d 732 (1984).
Limited by New York v. Harris, 495 U.S. 14 (1990)
In fight of these principles, we decline to apply the exclusionary rule in this context because the rule in Payton was designed to protect the physical integrity of the home; it was not intended to grant criminal suspects, like Harris, protection for statements made outside their premises where the police have probable cause to arrest the suspect for committing a crime.
Distinguished
Distinguished by People v. Shaw, 2026 NY Slip Op 00961 (2026)
The third-party tenant's consent in this case simply bears no relationship to any Payton violation against defendant, and the exclusionary rule is inapplicable.
Distinguished by Com. of Pa. v. Romero, 183 A.3d 364 (2018)
" We distinguish this dictum from the "Payton holding," wherein the Payton Court, resolving the narrow issue presented to it, concluded that warrantless entries into a home to arrest a suspect are unconstitutional.
Distinguished by People v. Spencer, 29 N.Y.3d 302 (2017)
Regarding defendant’s pretrial motion to suppress evidence, we reject defendant’s argument that his warrantless arrest violated Payton v New York (445 US 573 [1980]).
Distinguished by United States v. Medina, 19 F. Supp. 3d 518 (2014)
Even if coercive conduct without a physical entry could amount to a Payton violation, the NYPD’s conduct here is distinguishable from the extreme examples cited by Medina.
The opinion
Mr. Justice Powell,
concurring in United States v. Watson, supra, at 429, stated:
“But logic sometimes must defer to history and experience. The Court’s opinion emphasizes the historical sanction accorded warrantless felony arrests [in public places].”
In this case, however, neither history nor this Nation’s experience requires us to disregard the overriding respect for the sanctity of the home that has been embedded in our traditions since the origins of the Republic. 54
*602 IV
The parties have argued at some length about the practical consequences of a warrant requirement as a precondition to a felony arrest in the home. 55 In the absence of any evidence that. effective law enforcement has suffered in those States that already have such a requirement, see nn. 3, 47, supra, we are inclined to view such arguments with skepticism. More fundamentally, however, such arguments of policy must give way to a constitutional command that we consider to be unequivocal.
Finally, we note the State’s suggestion that only a search warrant based on probable cause to believe the suspect is at home at a given time can adequately protect the privacy interests at stake, and since such a warrant requirement is manifestly impractical, there need be no warrant of any kind. We find this ingenious argument unpersuasive. It is true that an arrest warrant requirement may afford less protection than a search warrant requirement, but it will suffice to interpose the magistrate’s determination of probable cause between the zealous officer and the citizen. If there is sufficient evidence of a citizen’s participation in a felony to persuade a judicial officer that his arrest is justified, it is constitutionally reason *603 able to require him to open his doors to the officers of the law. Thus, for Fourth Amendment purposes, an arrest warrant founded on probable cause implicitly carries with it the limited authority to enter a dwelling in which the suspect lives when there is reason to believe the suspect is within:
Because no arrest warrant' was obtained in either of these cases, the judgments must be reversed and the cases remanded to the New York Court of Appeals for further proceedings not inconsistent with this opinion.
It is so ordered.
There can be no doubt that Pitt’s address in the House of Commons in March 1763 echoed and re-echoed throughout the Colonies:
“ ‘The poorest man may in his cottage bid defiance to all the forces of the Crown. It may be frail; its roof may shake; the wind may blow through it; the storm may enter; the rain may enter; but the King of England cannot enter — all his force dares not cross the threshold of the ruined tenement!’” Miller v. United States, 357 U. S., at 307.
The State of New York argues that the warrant requirement will pressure police to seek warrants and make arrests too hurriedly, thus increasing the likelihood of arresting innocent people; that it will divert scarce resources thereby interfering with the police’s ability to do thorough investigations; that it will penalize the police for deliberate planning; and that it will lead to more injuries. Appellants counter that careful planning is possible and that the police need not rush to get a warrant, because if an exigency arises necessitating immediate arrest in the course of an orderly investigation, arrest without a warrant is permissible; that the warrant procedure will decrease the likelihood that an innocent person will be arrested; that the inconvenience of obtaining a warrant and the potential for diversion of resources is exaggerated by the State; and that there is no basis for the assertion that the time required to obtain a warrant would create peril.