Brigham City v. Stuart
Stuart and two other defendants filed a motion to suppress evidence obtained by the Brigham City police in a warrantless entry of a house. Four police officers, responding to a complaint about a loud party, were approaching the house when they saw through the windows that Stuart and three other adults were restraining a juvenile. The officers opened a screen door, entered the house, and arrested the four adults. The four adults were charged with charged with contributing to the delinquency of a minor, disorderly conduct and intoxication. Stuart and two other defendants filed a motion to suppress evidence obtained in the warrantless entry of the house. Finding that the police officers' entry to the house was not supported by "exigent circumstances," the trial court granted the motion, and the court of appeals affirmed.
On appeal to the Supreme Court of Utah, Brigham City argued that (1) the "emergency aid doctrine" justified the officers' entry and (2) "exigent circumstances" were present because the restrained juvenile faced immediate harm. The supreme court rejected both arguments, ruling that (1) at the time of entry, the police officers did not have a reasonable belief that emergency aid was required to preserve life or prevent serious injury and (2) although the police officers have more leeway for entry in light of exigent circumstances, the circumstances in the case did not justify the intrusion. Thus, the supreme court affirmed the court of appeals decision, holding that the evidence should be suppressed.
Questions Presented:
1. Does the "emergency aid exception" to the warrant requirement recognized in Mincey v. Arizona, 437 U.S. 385 (1978), turn on an officer's subjective motivation for entering the
home?
2. Was the gravity of the "emergency" or "exigency" sufficient to justify, under the Fourth Amendment, the officers' entry into the home to stop the fight?
