Legal Reasoning

Introduction:

This paper aims to draft what I believe to be the US Supreme Court opinion for the case of Brigham City, Utah V. Stuart including the concurring and dissenting opinions. Knowledge from of the Fourth Amendments will be used to draft the opinion or opinions and an identification of particular justices with each of the opinion will be made as much as possible.

In as much that the Supreme Court has made the decision (May 22, 2006) on the matter, at the time of theis, this paper is now converted into a digest of the case but still following the structure of the original instruction that is to draft (now to analyze) the opinion (now the decision) of the Supreme Court with the concurring and dissenting opinions.

2. Analysis:

Facts:  The policemen were responding to a 3 a.m. call about a loud party by arriving at the house in question when the said policemen heard shouting inside said house. They then proceeded down the driveway, and saw two juveniles drinking beer in the backyard. The police then entered the yard where they saw through a screen door and windows an altercation in the kitchen between four adults and a juvenile, who punched one of the adults, causing him to spit blood in a sink. (Cornell Law School, n.d.) (Paraphrasing made)

An officer from the group of policemen opened the screen door and announced the officers’ presence. After having been ignored amid the commotion, the officer entered the kitchen and again cried out, whereupon the squabble gradually subsided. The officers made an arrest of the respondents and charged them with contributing to the delinquency of a minor and related offenses. The trial court granted private respondents’ motion to suppress all evidence obtained after the officers entered the home on the ground that the warrantless entry violated the Fourth Amendment, and the Utah Court of Appeals affirmed.

The State Supreme Court affirmed further by holding that the injury caused by the juvenile’s punch was insufficient to trigger the “emergency aid doctrine” because it did not give rise to an objectively reasonable belief that an unconscious, semiconscious, or missing person feared injured or dead was in the home. In addition, the same Supreme Court suggested the doctrine was inapplicable because the officers had not sought to assist the injured adult but had acted exclusively in a law enforcement capacity. It further held that the entry did not fall within the exigent circumstances exception to the warrant requirement.  (Cornell Law School, n.d.) (Paraphrasing made)

The issue in said case is whether or not the police may enter a home without a warrant under the given circumstances as described above.

The US Federal Supreme Court held that the police may enter a home without a warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury. The Supreme Court said:

Because the Fourth Amendment’s ultimate touchstone is “reasonableness,” the warrant requirement is subject to certain exceptions. For example, one exigency obviating the requirement is the need to render emergency assistance to occupants of private property who are seriously injured or threatened with such injury. Mincey v. Arizona, 437 U.S. 385. This Court has repeatedly rejected respondents’ contention that, in assessing the reasonableness of an entry, consideration should be given to the subjective motivations of individual officers. Because the officers’ subjective motivation is irrelevant, Bond v. United States, 529 U. S. 334, n. 2, it does not matter here whether they entered the kitchen to arrest respondents and gather evidence or to assist the injured and prevent further violence. Indianapolis v. Edmond, 531 U. S. 32, and Florida v. Wells, 495 U. S. 1, distinguished.

Relying on this Court’s holding in Welsh v. Wisconsin, 466 U. S. 740, that “an important factor to be considered when determining whether any exigency exists is the gravity of the underlying offense for which the arrest is being made,” respondents further contend that their conduct was not serious enough to justify the officers’ intrusion into the home. This contention is misplaced. In Welsh, the “only potential emergency” confronting the officers was the need to preserve evidence of the suspect’s blood-alcohol level, an exigency the Court held insufficient under the circumstances to justify a warrantless entry into the suspect’s home. Ibid. Here, the officers were confronted with ongoing violence occurring within the home, a situation Welsh did not address. (Cornell Law School, n.d.)

The Supreme Court further added that the officers’ entry here was plainly reasonable under the circumstances. It said that given the tumult at the house when they arrived, it was obvious that knocking on the front door would have been futile and that moreover, in light of the fracas they observed in the kitchen, the officers had an objectively reasonable basis for believing both that the injured adult might need help and that the violence was just beginning.

The court explained that nothing in the Fourth Amendment required them to wait until another blow rendered someone unconscious, semiconscious, or worse before entering. It further said: “The manner of their entry was also reasonable, since nobody heard the first announcement of their presence, and it was only after the announcing officer stepped into the kitchen and announced himself again that the tumult subsided. That announcement was at least equivalent to a knock on the screen door and, under the circumstances; there was no violation of the Fourth Amendment’s knock-and-announce rule. Furthermore, once the announcement was made, the officers were free to enter; it would serve no purpose to make them stand dumbly at the door awaiting a response, while those within brawled on, oblivious to their presence.” (Cornell Law School, n.d.) (Paraphrasing made)

The Supreme Court reversed and remanded the UTAH Supreme Court’s decision via a unanimous decision, hence there, is no dissenting opinion.  Chief Justice ROBERTS delivered the opinion for a unanimous Court while Justice STEVENS filed a concurring opinion.

3. Conclusion:

The case was unique in the sense that a state court namely the UTAH Supreme Court, which has decided unanimously, was reversed by the US Federal Supreme Court also unanimously. The case involves the interpretation of the Fourth Amendment where there the policemen were upheld in effecting the arrest in the absence of the warrant since the case is case falling under justified exceptions.

Bibliography:

Bond v. United States, 529 U. S.

Cornell Law School, (n.d.), BRIGHAM CITY v. STUART (No. 05-502) , 2005 UT 13, 122 P. 3d 506, reversed and remanded, {www document}  URL  http://www.law.cornell.edu/supct/html/05-502.ZS.html, Accessed June 10,2006.
Florida v. Wells, 495 U. S. 1

Fourth Amendment , United States Constitution
Indianapolis v. Edmond, 531 U. S. 32

Mincey v. Arizona, 437 U. S. 385
Welsh v. Wisconsin, 466 U. S. 740