The US Supreme Court on Wednesday ruled unanimously in Lange v. California that, under the Fourth Amendment, pursuit of a fleeing misdemeanor suspect does not always or categorically qualify as an exigent circumstance justifying warrantless entry into a home.
Arthur Gregory Lange was driving home when a California highway patrol officer began following him with the intent to conduct a traffic stop. Lange was playing his “music very loudly” and honking his horn despite there being no other vehicles nearby. The officer followed Lange for several blocks before activating his overhead lights. Lange turned into his driveway, pulled into his garage, and began closing his garage door. The officer followed Lange and interrupted the garage door from closing. The officer then questioned Lange and ultimately charged him with two vehicle code misdemeanors and an infraction.
At trial, Lange moved to suppress the evidence obtained in the garage, arguing that the officer violated his Fourth Amendment rights when he entered Lange’s home without a warrant. However, the lower court ruled in favor of the officer, finding that the officer had probable cause.
The Supreme Court’s opinion, delivered by Justice Elena Kagan, vacated and remanded the lower court’s decision, holding that “the flight of a suspected misdemeanant does not always justify entry into a home. An officer must consider all the circumstances in a pursuit case to determine whether there is a law enforcement emergency.”