Thompson v. Louisiana

In Thompson v. Louisiana, 469 U.S. 17 (1984), a woman shot her husband, attempted suicide by overdosing on pills, and then, changing her mind, called her daughter for help. The daughter contacted the police, who entered the unconscious mother's house, transported her to the hospital, and later searched the house for two hours. Id. at 18-19. The officers entered the defendant's house in response to a homicide call, discovered the body of the victim, then secured the scene and transported the defendant to the hospital because of an apparent drug overdose. Id. at 18-19. Thirty-five minutes later, two homicide investigators arrived at the home and conducted a two-hour "exploratory search" of the defendant's entire house. Id. at 18-19. The officers found a gun inside a chest of drawers located in the same room as the victim's body, a torn up note in a wastebasket in an adjoining room and another note inside an envelope on top of a chest of drawers. Id. at 19. Relying on Mincey v. Arizona, 437 U.S. 385 (1978), the United States Supreme Court reiterated that a warrantless search of the defendant's home was not constitutional simply because it was the scene of a recent homicide. Id. at 21. The Court observed that, while less intrusive than in Mincey, the officers' two-hour general search of Thompson's entire house was still "a significant intrusion," particularly because the evidence seized was not discovered in plain view when the officers were legitimately inside the house to render emergency aid. Id. at 22. Finding that the purpose of the second search was unrelated to the purpose of the initial entry, the Supreme Court held the warrantless second search to be unreasonable. Although the Supreme Court did not uphold the two-hour search, it acknowledged that the mother's medical emergency "would have justified the authorities in seizing evidence under the plain-view doctrine while they were in the mother's house to offer her assistance." Id. at 22.