Payton v. New York

Payton and Riddick asked for the New York Court of Appeals decision to be reviewed by the U.S. Supreme Court. Noting that both state and federal courts have disagreed over whether the Fourth Amendment prohibits a warrantless arrest in a person's home, the Supreme Court decided to hear the case. In the 1976 case United States v. Watson, the Court held that a police officer need not obtain an arrest warrant before arresting a person suspected of a felony in a public place. However, the Court refused to extend the rule of Watson to arrests occurring within the home.

In an opinion written by Justice John Paul Stevens, the Court concluded that, absent special or "exigent" circumstances, the Fourth Amendment prohibits police officers from entering a person's home to make an arrest without first obtaining an arrest warrant.

The Court began by noting that the Fourth Amendment was designed to protect the privacy of individuals in various settings, and that in no setting "is the zone of privacy more clearly defined than when bounded by the unambiguous physical dimensions of an individual's home." The Court then rejected New York's argument that, because warrantless arrests in the home were allowed in common law England, the founders did not intend the Fourth Amendment to prohibit such arrests. Examining old English cases and the works of English legal commentators, the Court concluded that there was no general common law rule regarding whether a police officer needed to obtain a warrant before entering a home to make an arrest at the time the Fourth Amendment was adopted.

The Court also rejected New York's argument that requiring a warrant before entering a home to make an arrest would have practical consequences for law enforcement. The Court noted that several states had already required a warrant, and there was no evidence that law enforcement was hampered in making arrests in any of these states. Thus, the Court concluded that "neither history nor this Nation's experience requires us to disregard the overriding respect for the sanctity of the home that has been embedded in our traditions since the origins of the Republic," and held that the Fourth Amendment requires an officer to obtain an arrest warrant before entering a person's home to make an arrest, in the absence of exigent circumstances.