Vale v. Louisiana

Vale v. Louisiana
Supreme Court of the United States
Decided June 22, 1970
Full case nameVale v. Louisiana
Citations399 U.S. 30 (more)
Holding
A search of a suspect's house is not "incident to the arrest" when the suspect's arrest took place outside.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
Hugo Black · William O. Douglas
John M. Harlan II · William J. Brennan Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Case opinions
MajorityStewart
DissentBlack, joined by Burger
Blackmun took no part in the consideration or decision of the case.
Laws applied
Amendment IV

Vale v. Louisiana, 399 U.S. 30 (1970), was a United States Supreme Court case in which the Court held that a search of a suspect's house is not "incident to the arrest" when the suspect's arrest took place outside. The police officers therefore required a search warrant.[1]

Significance

With regards to the exclusionary rule, the police officers also claimed that exigent circumstances justified the warrantless search of the house: they claimed to be concerned that someone would have destroyed the narcotics in the home if they waited to get a search warrant.[1] Vale demonstrates that courts are not supposed to engage in good faith analysis about search warrant exceptions. If police officers are wrong and there are no exigent circumstances present, then the search is illegal and the exclusionary rule applies to any collected evidence.[2]

References

  1. ^ a b Vale v. Louisiana, 399 U.S. 30 (1970).
  2. ^ Groot, Roger D. (1981). "Arrests in Private Dwellings". Virginia Law Review. 67 (2): 275–285. doi:10.2307/1072692. ISSN 0042-6601. JSTOR 1072692.
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