Vale v. Louisiana, 399 U.S. 30 (1970)

Facts

Officers observed a vehicle approach Vale’s home.  Vale came out to meet the vehicle, looking around the entire time.  Vale returned to his house then went back to the vehicle.  Officers assumed a narcotics sale was occurring and went to intervene.  Vale returned to his house but was told to stop at his front steps.  Officers entered the home based on the witnessed transaction and discovered narcotics in a rear bedroom.

Procedural History

The Louisiana Supreme Court held that the search of the house did not violate the Fourth Amendment because it occurred in the immediate vicinity of the arrest.

Issue(s)

Did the Louisiana Supreme Court err?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that a search may be incident to an arrest only if it substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest.  The officers here were not responding to an emergency and were not in his pursuit of a fleeing felon.  We decline to hold that an arrest on the street can provide its own exigent circumstance so as to justify a warrantless search of the arrestee’s house.

Judgment/Outcome

The Court reversed and remanded the judgment of the Louisiana Supreme Court.