Lange v. California

Background

A driver who had been honking and playing loud music was followed by a California highway patrol officer. The driver pulled into his attached garage instead of stopping, and the officer followed, questioned him, and later tested him for intoxication. The State charged the driver with a misdemeanor DUI and the driver asked a court to suppress the evidence gathered after the officer entered the garage without a warrant. The California Court of Appeal said chasing a misdemeanant always allows warrantless home entry, and the State Supreme Court denied review.

Reasoning

The Court addressed whether pursuit of a fleeing misdemeanor suspect always counts as an emergency that allows warrantless entry. It held that it does not. The Fourth Amendment generally requires a warrant to enter a home, and exceptions for “exigent circumstances” must be decided on the facts of each case. The Court explained that only when an actual emergency exists—such as imminent harm, destruction of evidence, or likely escape—may officers enter without waiting for a warrant. The Court also found that the common law at the Nation’s founding did not support a blanket rule for misdemeanors. The Court vacated the California Court of Appeal’s categorical rule and sent the case back for further proceedings.

Real world impact

Police can still enter homes without a warrant in many pursuit cases, but officers must point to particular emergencies in each situation. Routine misdemeanors (traffic, noise, etc.) will not automatically allow home entry; officers must weigh the facts and, when feasible, get a warrant. The decision sends the question back to the lower court to apply this case-by-case test.

Dissents or concurrances

Several Justices agreed on the outcome but not the reasoning. One concurrence said the practical effect will be small; another emphasized historical exceptions and limits on excluding evidence; the Chief Justice argued that hot pursuit itself should be a standalone exception.