Payton v. New York

The Court's ruling reiterated the strong privacy protection people enjoy in their homes, and reaffirmed that the police may not enter a person's home without consent except where they obtain a warrant, or in other very narrow circumstances.

The Fourth Amendment to the Constitution provides that the "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause . . . " The Fourth Amendment is based, in large part, on English common law. Thus, as early as 1886, in the case of Boyd v. United States, the Supreme Court noted that the Fourth Amendment protects people against "all invasions on the part of the government and its employees of the sanctity of a man's home and the privacies of life." In Payton, the strengths and limits of this theory were put to the test before the Supreme Court.

The Payton case involved two separate criminal prosecutions in the state of New York. In the first case, Theodore Payton was suspected of murder by New York City detectives. After investigating Payton for two days, the police decided that they had probable cause to believe that Payton had committed the murders, and went to his apartment to arrest him. The police entered the apartment based on a New York state statute which permitted officers to enter a home without a search or arrest warrant to arrest a person if they had probable cause to believe that the person committed a felony. Although Payton was not at home, the police discovered a bullet shell casing, which was used against Payton in his trial.

In the second case, Obie Riddick was suspected of two armed robberies. The police, acting pursuant to the New York statute, arrested Riddick in his home without obtaining a warrant. During the arrest, the police discovered narcotics and narcotics paraphernalia. Riddick was tried and convicted on narcotics charges.

Both Payton and Riddick moved to suppress the evidence against them discovered by the police, arguing that the police violated their Fourth Amendment right to be free from unreasonable seizures by entering their homes without a warrant. The state trial courts denied their motions, and both were convicted. They each appealed their convictions to the New York Court of Appeals which, in a single opinion, agreed with the trial courts that the Fourth Amendment does not require a police officer to obtain a warrant before entering a home to arrest a person for committing a felony.