Lange v California, (2021), was a United States Supreme Court case involving the exigent circumstances requirement related to the Fourth Amendment to the United States Constitution. The Court ruled unanimously that the warrantless entry into a home by police in pursuit of a misdemeanant is not unequivocally justified.
Background.
In October 2016, a California highway patrol officer witnessed Arthur Lange driving while playing loud music and honking his horn. Believing Lange to be in violation of California traffic law, the officer attempted to perform a traffic stop. Lange drove to his garage and then closed the garage but the officer, who had followed him to his home, entered the garage and began to question Lange. After smelling alcohol on his breath and conducting a field sobriety test, the officer arrested Lange and charged him with driving under the influence and a noise infraction.
Lange attempted to argue at trial that the officer's entry into his garage without a warrant had violated his Fourth Amendment rights and therefore evidence related to the case had to be suppressed. The prosecution argued that under the "hot pursuit doctrine" the officer had probable cause to enter the garage because Lange had committed a misdemeanor when he failed to stop for the officer. The court subsequently denied Lange's motion to suppress the evidence. As a result, Lange's driver's license was suspended for a period of one year.
Initial appeals.
Lange filed a suit to overturn the suspension of his license in civil court which was accepted after the court determined his arrest to be unlawful. However, the Sonoma County Superior Court affirmed the decision of the trial court to deny Lange's motion to suppress. The California Court of Appeal also upheld the conviction. In July 2020, Lange applied for a writ of certiorari from the Supreme Court which was granted in October 2020.