Vale v. Louisiana

Background

Donald Vale was tried and convicted in Louisiana for possessing heroin and sentenced to 15 years. On April 24, 1967, officers with two arrest warrants watched the house where Vale was living. They saw a green 1958 Chevrolet stop, Vale leave the house and lean into the car, and the driver (known addict Arizzio Saucier) hurriedly put something in his mouth. Officers approached, arrested Vale and Saucier near the front steps, told Vale they would search the house, and entered. After a quick check showed no one inside, Vale’s mother and brother returned shortly thereafter. A search of a rear bedroom uncovered narcotics that were used at trial.

Reasoning

The Court asked whether an arrest on the street allows police to search the arrestee’s house without a warrant. Relying on Chimel, the majority held that a search incident to arrest must be limited to the area within the arrestee’s immediate reach and that an arrest outside the dwelling does not justify a warrantless house search. The Court found no consent, emergency, hot pursuit, or other "exceptional" circumstance shown by the State and concluded the Louisiana court erred in admitting the evidence. The judgment was reversed and the case remanded.

Real world impact

The decision restricts when police may enter and search a home without a warrant after arresting someone outside. Police must show an established exception to the warrant requirement before searching a dwelling, or obtain a search warrant. The ruling led to exclusion of the seized narcotics in this case.

Dissents or concurrances

Justice Black (joined by the Chief Justice) dissented, arguing the officers acted reasonably under the circumstances and that the risk of destruction of evidence justified the immediate search.