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The U.S. Supreme Court on May 22 ruled unanimously that police can enter a home without a warrant when they have neither knocked nor announced their presence if they have an objectively reasonable basis to believe that someone inside the home has been seriously injured or is imminently threatened with injury. Brigham City v. Stuart, No. 05-502. Police were called to a house in Brigham City, Utah, after complaints about a loud party. Going around the back, they saw what they thought was a scuffle involving four adults and a juvenile. The juvenile punched one of the adults, causing him to spit blood in a sink. The police opened a screen door, announced their presence by yelling “Police”-which went unnoticed amidst the tumult-and, without a warrant, entered the house. Four adults were arrested and charged with misdemeanors: disorderly conduct, intoxication and contributing to the delinquency of a minor. A Utah trial court suppressed all of the evidence police obtained after they entered the home on the ground that the warrantless entry violated the Fourth Amendment. An intermediate appellate court affirmed, as did the Utah Supreme Court, which held 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. Moreover, the doctrine was inapplicable because the officers hadn’t assisted the injured adult but acted exclusively in a law enforcement capacity. The justices reversed. Writing for the court, Chief Justice John G. Roberts Jr. said that because the Fourth Amendment’s ultimate touchstone is “reasonableness,” the warrant requirement is subject to exceptions, such as the need to render emergency assistance. Also, high court precedent holds that in assessing the reasonableness of an entry, the subjective motivations of individual officers are not relevant. Thus, it did not matter whether police entered the kitchen to make arrests or to assist the injured and prevent further violence. Their entry was plainly reasonable under the circumstances. Given the tumult at the house when they arrived, it was obvious that knocking on the front door would have been futile. Moreover, the officers had an objectively reasonable basis for believing both that the injured adult might need help and that the violence was just beginning. Nothing in the Fourth Amendment required them to wait until another blow rendered someone unconscious or worse before entering. The manner of the police entry was also reasonable, since nobody heard the first announcement of their presence. Once the announcement was made, the officers were free to enter: “The role of a peace officer includes preventing violence and restoring order, not simply rendering first aid to casualties; an officer is not like a boxing (or hockey) referee, poised to stop a bout only if it becomes too one-sided,” Roberts wrote.

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