There are some circumstances where law enforcement officers may enter your home if they have reasonable suspicion that you committed a misdemeanor offense, however, misdemeanor driving under the influence is no longer a class of offense for which law enforcement may always enter without a warrant. In the case Lange v. California, the United States Supreme Court addresses the issue of warrantless entries for misdemeanor offenses.
Lange V. California
Case History
The defendant, Arthur Lange (Lange), was driving home when he drove past a highway patrol officer. Lange was acting oddly, playing loud music and honking his horn repeatedly. When the officer observed Lange’s behavior, he began to follow Lange home. The officer did not have to follow long, as Lange was nearly home when he drove past the officer. Lange drove onto his driveway and went into his garage. After Lange got out of his vehicle, the officer followed behind him into his garage. At that time, the officer began questioning Lange. During the officer’s questioning, the officer noticed signs of Lange’s intoxication and subjected him to a field sobriety test, which he failed. The officer arrested Lange and submitted him for a blood alcohol test. At the time of the test, Lange’s blood alcohol content was more than three times the legal limit of 0.08. Following the test, Lange was charged with misdemeanor driving under the influence (DUI).
Lang moved to suppress testimony from the officers questioning in his garage and the resulting blood alcohol test. Lang argued that the officer’s warrantless entry of his home had violated his Fourth Amendment right against unreasonable searches and seizures. The prosecution argued that the Court should not suppress the evidence because the officer had probable cause to arrest Lang for another misdemeanor, failing to comply with a police signal. In cases where exigent circumstances are present or require immediate action, police officers are allowed to perform warrantless entries. The Court denied Lange’s motion to suppress the evidence, and the appellate division affirmed the lower court’s decision.
At the appellate level, the Court ruled in favor of the state, denying suppression of the evidence. The appellate court held that the officer lawfully arrested Lang because his failure to pull over when the officer flashed the lights created probable cause for an arrest. The appeals court construed Lange entering his garage as an attempt to avoid arrest. Because of that perceived attempt, the Court said that exigent circumstances were present and warrantless entry was proper. Lange petitioned the California Supreme Court, which denied review. Following the California Supreme Court’s denial, the United States Supreme Court accepted the case to resolve the question of whether the Fourth Amendment legally allows an officer to enter a person’s home without a warrant in any situation where they are in “hot pursuit” of a misdemeanor suspect.
United States Supreme Court Decision
The US Supreme Court considered the application of exigent circumstances in cases where the Fourth Amendment applies, searches and seizures. The Court remarked that the applicable standard for the Fourth Amendment is reasonableness. The reasonableness standard requires that law enforcement have a warrant when entering a person’s home for an arrest. Even though the Fourth Amendment generally requires a warrant for entry, the Court recognized that there could be exigent circumstances that may justify a warrantless entry. The Court provided examples, such as when the police provide assistance in a dangerous situation or prevent a suspect’s escape.
The Court considered whether all incidents where a suspect is fleeing—also known as a categorical approach—support warrantless entry in all similar circumstances or if a case-by-case assessment is required. If a case-by-case analysis is needed, the Court applies a “totality of the circumstances test” or an analysis of certain factors present in the case to review. The Court notes the importance of the Fourth Amendment, with particular emphasis on the protection of the home. Because security and privacy in a person’s home have been an integral part of our country’s history, the Court has been hesitant to expand the circumstances in which a warrantless entry into the home is proper.
The prosecution’s arguments suggested that an officer should always be allowed warrantless entry where a suspect is fleeing because it is an exigent circumstance. They supported their argument with case law involving the hot pursuit of a felony suspect. The Court considered the evidence but found that states categorize crimes differently, with some more serious crimes being considered a misdemeanor and some less severe. Because interpretation of a misdemeanor varies so widely, the Court suggested that a case-by-case basis is more appropriate when determining if exigent circumstances support warrantless entry. The Court, however, found that interpretation of the Fourth Amendment suggested that a warrantless entry into a fleeing suspect’s home is not always proper.
The Court ultimately rejected the prosecution’s argument that a fleeing misdemeanor suspect amounted to an exigent circumstance that would give an officer broad authority for warrantless entry. The Court states that a fleeing suspect may require law enforcement to act quickly but that “no evidence suggests that every case of misdemeanor flight creates such a need.” Because the California Court of Appeals applied the categorical approach, the Appeal’s court judgment was voided, and the case was sent back for review.
Florida DUI Lawyer
For more information about DUI charges in Florida, including how the state’s laws relating to warrantless entry affect you, it is vital that you talk with an experienced criminal defense attorney. Koberlein Law Offices’ experienced DUI attorneys are here for you. We are devoted to protecting the rights of Floridians who have been charged with criminal offenses, including DUIs. To learn more, reach out to Koberlein Law Offices today by calling us toll-free at 877.556.2889 or contacting us online.
