Brigham City v. Stuart

In Brigham City v. Stuart (2006) 547 U.S. 398, the police officers arrived at a house and heard from within "'an altercation occurring, some kind of fight'" and "'thumping and crashing.'" (Brigham City v. Stuart, supra, 547 U.S. at p. 406 164 L.Ed.2d. at p. 659.) They determined the noise was coming from the back of the house and that knocking on the front door would be futile, so they went around back. (Ibid.) Through a window, they saw a juvenile strike "one of the adults in the face, sending the adult to the sink spitting blood." (Ibid.) Then they saw several people try to restrain the juvenile so forcefully they displaced a refrigerator. (Id. at p. 401.) Based on this evidence, the United States Supreme Court held that the "officers were confronted with ongoing violence occurring within the home," which justified the entry of the officers into the home after announcing themselves outside the screen door. (Id. at pp. 405-406.) The United States Supreme Court stated: "It is a '"basic principle of Fourth Amendment law that searches and seizures inside a home without a warrant are presumptively unreasonable."'Nevertheless, because the ultimate touchstone of the Fourth Amendment is 'reasonableness,' the warrant requirement is subject to certain exceptions. We have held, for example, that law enforcement officers may make a warrantless entry onto private property to fight a fire and investigate its cause, to prevent the imminent destruction of evidence, or to engage in '"hot pursuit"' of a fleeing suspect. 'Warrants are generally required to search a person's home or his person unless "the exigencies of the situation" make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment.' One exigency obviating the requirement of a warrant is the need to assist persons who are seriously injured or threatened with such injury. '"The need to protect or preserve life or avoid serious injury is justification for what would be otherwise illegal absent an exigency or emergency."' Accordingly, law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury." The Supreme Court 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." (Id. at p. 400.)