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 Blackmun,
concurring;
I joined the Court’s opinion in United States v. Watson, 423 U. S. 411 (1976), upholding, on probable cause, the warrant-less arrest in a public place. I, of course, am still of the view that the decision in Watson is correct. The Court’s balancing of the competing governmental and individual interests properly occasioned that result. Where, however, the warrantless arrest is in the suspect’s home, that same balancing requires that, absent exigent. circumstances, the result be the other way. The suspect’s interest in the sanctity of his home then outweighs the governmental interests.
I therefore join the Court’s opinion, firm in the conviction that the result in Watson and the result here, although opposite, are fully justified by history and by the Fourth Amendment.