Adair v. Williams
In Adair v. Williams, 24 Ariz. 422, 210 P. 853 (1922), police officers had entered the Adairs' home without a warrant and then arrested them for allegedly committing the misdemeanor offense of unlawful cohabitation in the officers' presence. The Adairs filed a claim for false imprisonment and, following a trial, appealed from an adverse jury verdict. The supreme court reversed, based on an erroneous jury instruction.
The court determined that the officers' warrantless entry into the home was unlawful and, therefore, that their subsequent warrantless arrest of the Adairs was likewise unlawful. "An officer is not justified either in making a warrantless entry into a house for the mere purpose of placing himself in a position where he may observe the commission of a misdemeanor or in thereupon making an arrest therefor." Id. at 432, 210 P. at 856.
The court thus held that the officers could not defend against the false imprisonment claim, as the trial court had instructed the jury, on the ground that the officers had arrested the Adairs without a warrant "upon a good-faith belief in their guilt." Id. at 436, 210 P. at 857.