547 U.S. 398 (2006)
In the early morning hours of July 23, 2000, four police officers in Brigham City, Utah responded to a call regarding a loud party at a residence.1 Upon arriving at the house around 3 a.m., the officers heard shouting from inside and proceeded down the driveway to investigate.2 They observed two juveniles drinking beer in the backyard and then saw through a screen door and windows an altercation taking place in the kitchen.3
Four adults were attempting to restrain a juvenile who eventually broke free, swung a fist, and struck one of the adults in the face.4 The officer testified that he observed the victim of the blow spitting blood into a nearby sink.5 The other adults continued to try to restrain the juvenile, pressing him up against a refrigerator with such force that the refrigerator began moving across the floor.6 One officer opened the screen door and announced the officers' presence, but amid the tumult nobody noticed, so the officer entered the kitchen and announced again until the occupants became aware of the police and the altercation ceased.7
The officers arrested respondents and charged them with contributing to the delinquency of a minor, disorderly conduct, and intoxication.8 In the trial court respondents filed a motion to suppress all evidence obtained after the officers entered the home, arguing that the warrantless entry violated the Fourth Amendment. The court granted the motion.9 The Utah Court of Appeals affirmed the suppression ruling.10
Before the Supreme Court of Utah, Brigham City argued that the entry was reasonable under the emergency aid doctrine or the exigent circumstances exception, but the court rejected both contentions and affirmed over two dissenters.11 The United States Supreme Court granted certiorari in light of differences among state courts and the Courts of Appeals concerning the appropriate Fourth Amendment standard governing warrantless entry by law enforcement in an emergency situation.12
Whether 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?13
It is a basic principle of Fourth Amendment law that searches and seizures inside a home without a warrant are presumptively unreasonable.14 Nevertheless, because the ultimate touchstone of the Fourth Amendment is reasonableness, the warrant requirement is subject to exceptions when the exigencies of the situation make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment.15 One such exigency is the need to assist persons who are seriously injured or threatened with such injury.16 This permits law enforcement officers to enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.17
Yes. The officers observed through a screen door and windows a juvenile break free and strike an adult in the face, sending the adult to the sink spitting blood.18 Other adults pressed the juvenile against a refrigerator that moved across the floor amid ongoing shouting and tumult at 3 a.m.19 This provided an objectively reasonable basis for believing an occupant was injured or imminently threatened.20 The officers' subjective motivations in entering to arrest or assist are irrelevant under the Fourth Amendment.21
The manner of entry, by opening the screen door and announcing presence twice until the altercation ceased, was also reasonable given the futility of knocking amid the noise.
Related opinions on this issue
This is an odd flyspeck of a case.24 The charges that have been pending against respondents for the past six years are minor offenses.25 Two of these offenses could have been proved by evidence gathered by the responding officers before they entered the home.26
The Utah Supreme Court has made clear that the Utah Constitution provides greater protection to the privacy of the home than does the Fourth Amendment.27 Justice Stevens would have denied certiorari to permit the state courts to decide the question under state law.28 Federal interests are not offended when a state elects to provide greater protection for its citizens.29