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Monday, May 22, 2006

Brigham City: Reasonable Entry into Home

In Brigham City, Utah v. Stuart, No. 05-502 (May 22, 2006), the Supreme Court held that 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 an injury.
Upon arrving at a house, the police heard schouting from inside, and saw an altercation in which one person was was struck by another. The police entered the house. The Utah Supreme Cvourt held that the police lacked probable cause,because the cirmstances were insufficient to trigger the "emergency aid doctrine."
Reversing, the Supreme Court held that the state of mind of police is irrelevant to the reasonableness of their search. The Court found the entry reaonable in the circumstances. The police had an objective, reasonable basis for believing that an injured adult needed help and that the violence was just beginning. The police was not required to wait at the door while the fight ‘brawled on" and the injuries got more serious.