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 Rehnquist,
dissenting.
The Court today refers to both Payton and Riddick as involving “routine felony arrests.” I have no reason to dispute the- Court’s characterization of these arrests, but cannot refrain from commenting on the social implications of the result reached by the Court. Payton was arrested for the murder of the manager of a gas station; Riddick was arrested for two armed robberies. If these are indeed “routine felony arrests,” which culminated in convictions after' trial upheld by the state courts on appeal, surely something is amiss in the process of the administration of criminal justice whereby these convictions are now set aside by this Court under the exclusionary rule which we have imposed upon the States under *621 the Fourth and Fourteenth Amendments to the United States Constitution.
I fully concur in and join the dissenting opinion of Mr. Justice White. There is significant historical evidence that we have over the years misread the history of the Fourth Amendment in connection with searches, elevating the warrant requirement over the necessity for probable cause in a way which the Framers of that Amendment did not intend. See T. Taylor, Two Studies in Constitutional Interpretation 38-50 (1969). But one may accept all of that as stare decisis, and still feel deeply troubled by the transposition of these same errors into the area of actual arrests of felons within their houses with respect to whom there is probable cause to suspect guilt of the offense in question.