Case Summaries -- United States Supreme Court (June 23, 2021)

This post summarizes the United States Supreme Court’s decision in Lange v. California, 594 U.S. ___, ___ S. Ct. ___ (June 23, 2021). This summary will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to present. Flight of a person suspected of a misdemeanor offense does not categorically justify an officer’s warrantless entry into a home. Lange v. California, 594 U.S. ___, ___ S. Ct. ___ (June 23, 2021). In this case, the Court held, in an opinion by Justice Kagan, that the flight of a person suspected of a misdemeanor offense does not categorically justify an officer’s warrantless entry into a home.  Instead, an officer must consider all the circumstances in a case involving the pursuit of a suspected misdemeanant to determine whether there is an exigency that would excuse the warrant requirement. A California highway patrol officer attempted to stop the petitioner Lange’s car after observing him driving while playing loud music through his open windows and repeatedly honking his horn. Lange, who was within 100 feet of his home, did not stop.  Instead, he drove into his attached garage. The officer followed Lange into the garage, where he questioned Lange and saw that Lange was impaired. Lange was subsequently charged with the misdemeanor of driving under the influence of alcohol and a noise infraction. Lange moved to suppress the evidence obtained after the officer entered his garage, arguing that the warrantless entry violated the Fourth Amendment. The trial court denied [...]