James v. Louisiana

Background

Police officers arrested a man near the intersection of Camp Street and Jackson Avenue in New Orleans after he got out of a car. They drove him more than two blocks to his home, broke open the door, and conducted a several-hour search that found drug equipment and a morphine tablet. A Louisiana jury convicted him and sentenced him to ten years. The Louisiana Supreme Court originally set aside the conviction because the search was warrantless, then on rehearing divided and affirmed. The United States Supreme Court agreed to review the case.

Reasoning

The Court asked whether the search of the home could be treated as a lawful search incident to the street arrest. It explained that a search incident to an arrest must be substantially contemporaneous with the arrest and limited to the area immediately around the arrest. Because the home search occurred hours later and more than two blocks away, it was not closely linked to the arrest. Under established protections against admitting evidence obtained in illegal searches, the Court held it was error to allow the seized items at trial. The Court reversed the conviction and sent the case back for further proceedings consistent with this ruling.

Real world impact

This decision limits police authority to search a person’s home without a warrant when the arrest happens elsewhere. Evidence found in such isolated home searches cannot be used against a defendant at trial. The case was reversed and remanded, so further steps can occur at the state level without the illegally seized evidence.