What did the US Supreme Court decide about warrantless entry in Brigham City v. Stuart?

Answer 1

Brigham City v. Stuart, 547 US 398 (2006)

Background

Police were dispatched to a Brigham City, Utah, address on complaints about a loud party. When they arrived, they saw minors drinking in the backyard, and heard shouting and sounds of a fight coming from the house. When police looked through the window, they saw a violent altercation between a teen and four adults. The police opened the door without entering and announced their presence, but were unnoticed due to the noise. Police then saw the teen punch one of the men in the mouth, sufficient to draw blood, which he spat in the sink.

The police entered and arrested the adults for contributing to the delinquency of a minor and other, related, charges. At trial, the judge granted the defendants' motion to suppress evidence gathered incident to the arrest, under the theory that the warrantless search constituted a Fourth Amendment prohibition against illegal search and seizure.

On appeal, the government argued the search was valid under the "emergency aid doctrine," an exception to Fourth Amendment protection, because the officers had seen one of the men become injured.

The Supreme Court of Utah disagreed, ruling emergency aid can only be rendered when there is an unconscious, semi-conscious, or missing person feared injured or dead. The Utah court also held the doctrine didn't apply because police were acting solely in a law enforcement capacity, not assisting the injured man.

Supreme Court Decision

In an 9-0 unanimous decision, the Court held that the police had acted reasonably, and that the "emergency aid doctrine" could be interpreted to mean police could enter a building without a warrant when they had reason to believe someone is "seriously injured, or threatened with serious injury." Per Mincey v. Arizona, 437 US 385 (1978), "The need to protect or preserve life or avoid serious injury is justification for what would otherwise be illegal absent an exigency or emergency."

The Supreme Court of Utah's decision was reversed, and the case was remanded to the lower courts.