Supreme Court Upholds 4th Amendment Protections
People v. Hammerlund
Court: Michigan Supreme Court ( Opinion )
Whether defendant’s constitutional right to be free from unreasonable seizures was violated when a police officer entered her home to complete her arrest for a misdemeanor offense; Payton v. New York; Whether she surrendered her Fourth Amendment rights; Reasonableness; Brigham City, Utah v. Stuart; People v. Mead; Probable cause; Dunaway v. New York; People v. Champion; People v. Oliver; United States v. Watson; People v. Hamilton; MCL 257.621(a); Distinguishing United States v. Santana; Public arrest; Reasonable expectation of privacy; Katz v. United States; Kentucky v. King; Exigent circumstances; Michigan v. Tyler; Hot pursuit exception to the warrant requirement; Welsh v. Wisconsin; Stanton v. Sims; Smith v. Stoneburner; The exclusionary rule; New York v. Harris
The court held that because the arrest was completed across the Fourth Amendment’s “firm line at the entrance of the home,” it was presumptively unreasonable. The prosecution failed to overcome this presumption, and the trial court and the Court of Appeals erred by holding otherwise. Thus, the court reversed the Court of Appeals’ judgment and remanded to the trial court. The issue was whether defendant’s constitutional right to be free from unreasonable seizures was violated when a police officer (S) entered her home to complete her arrest for a misdemeanor offense. S had probable cause to arrest her for failing to report an accident that caused damage to fixtures. There was no dispute that S completed defendant’s arrest inside her home. Unlike the defendant in Santana, defendant was not “exposed to public view, speech, hearing, and touch, as if she had been standing completely outside her house.” She was “never in a public place and possessed a reasonable expectation of privacy inside her home that she maintained throughout the encounter.” Initially, the court did not agree with the Court of Appeals’ conclusion that defendant “went further” than the Santana “defendant to expose herself to the public by approaching the doorway and ‘extending her arm beyond the threshold’ to retrieve her identification." It was beyond clear that she “had a reasonable constitutional expectation of privacy within her home. Answering a knock at the door or speaking with officers does not destroy an occupant’s right to maintain a reasonable expectation of privacy from unreasonable intrusion.” The only question was whether her “expectation of privacy remained intact when some portion of her hand or arm crossed the threshold to retrieve her property or if, by doing so, she somehow surrendered that expectation. Defendant manifested an intent to remain fully within her home by carefully standing several feet away from the door. [Her] expectation of privacy within her home was reasonable, and her action of reaching out over the threshold and retrieving her identification did not relinquish that reasonable expectation.” She was not exposed to public arrest, and thus, Santana did not apply to the facts here. S completed the arrest inside defendant’s “home, the place where the Constitution most protects her freedom from unreasonable governmental intrusion. Defendant was not subject to public arrest because she remained inside, she maintained her reasonable expectation of privacy, and her act of reaching out to retrieve her identification did not expose her to the public ‘as if she had been standing completely outside her house.’” Also, the circumstances were insufficient to justify the hot pursuit exception to the warrant requirement. The warrantless arrest was unreasonable under Payton.
The dissenting justices “would hold that there was no constitutional defect in the probable cause supporting the arrest and no constitutional defect stemming from the location of the arrest.” Even if a constitutional error did occur when S entered the home to complete the arrest, the holding in Harris “instructs that the exclusionary rule would not serve to bar admission of defendant’s self-incriminating statements made in [S’s] police vehicle or to the blood-alcohol-level tests administered” here. For these reasons, they believed the lower courts ultimately reached the correct conclusion and would affirm defendant’s convictions.