Payton Warrant

Payton Warrant

Payton v. New York, 445 U.S. 573, 588-89, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980), pro-hibits the warrantless arrest of a suspect inside his residence.

In United States v. Al-Azzawy, 784 F.2d 890, 893-95 (9th Cir.1985), the Court held that the Payton warrant rule applied when police officers surrounded the suspect's trailer, drew their weapons, and directed him (with a bullhorn) to exit the residence. Id. at 893.

The suspect only left his residence "under circumstances of extreme coercion." Id.