I. Introduction
The case of Brigham City, Utah v Stuart is a case covered by certain issues pertaining to the Fourth Amendment. The facts of the case include a situation where police officers of the Brigham City Police were dispatched to a complaint on a loud bash held at around three in the morning. Some of the officers were trying to look inside the house through the windows at the façade of the house but were unable to discern anything. The other police officers went out the backyard and immediately saw a commotion involving four adults restraining a juvenile. Upon seeing that the juvenile has thrown a punch and drew blood from one of the adults, the officers opened the backdoor and made their presence known by hollering at the people inside. When no one took notice of the officers, they were forced to enter the house and apprehend the four adults. They were charged with disorderly conduct, intoxication, and contributing to the delinquency of a minor. The defendants appealed to suppress the evidence that were uncovered inside the house due to the violation of their Fourth Amendment rights. The trial court, Utah Court of Appeals, and Utah Supreme Court all held that there were no exigent circumstances present in the said case to give good reason for the officers entering the house. Thus, the evidences collected were suppressed. However, the US Supreme Court reversed the decision of the three courts.
II. Issues of the Case
A major issue that involves the case is whether the police officers have followed a standard to which they could enter a house despite the absence of a warrant such that the Fourth Amendment rights of individuals are not compromised.
The Fourth Amendment is a law that protects the private person from any actions from the government that may compromise their privacy. These actions include searches and seizures of their property. In the American Revolution, this served as a means to fight off the legal document called writ of assistance. In the modern sense of the issue, the context revolves around the concept of probable cause. Basically, the government and law enforcement agencies are able to justify a search and seizure operation if they could establish that hey have ample probable cause to support their actions. This may well be the key element in the remanding of the US Supreme Court of the decisions made by the state courts in Utah regarding the Brigham case.
Establishing probable cause is stated in specific cases such as (1925) indicated that a search may be warranted if a “practical, nontechnical” assessment of the officer indicates that a possible criminal activity or contraband might be uncovered. Thus this establishes that it is in the officer’s discretion that arrests and seizures are made. Whether it is lawful or not is delegated to the courts. In the case of Brigham City, Utah v Stuart, the situation took place in the presence of the police officers and was regarded as an exigent circumstance, thus providing the police officers their much valued probable cause in making the arrests. However, those arrested could only be charged with the felonies that the police actually saw took place. They could not be charged with any other case based on evidence acquired after the arrest. ( v. , 1948) This means that the defense could challenge the presentation of evidence that were not a part of the altercation that took place when the police officers arrested the defendants.
III. Laws and Rules that Applies to the Case
There are several cases in the jurisdiction of the US that could serve as a precedent for the decision in the case. One such case is v. (1978). In the said case, the court held that exigent circumstances may call for the officers to enter a house without any warrant of arrest. Specifically, the case noted that the need of emergency aid is one of the more pressing factors that would allow police officers to enter a house. This is especially true if the apparent risk to safety is life threatening or necessary to prevent serious injury.
Another case applicable would be v. (1984). In this case, the determination on whether a specific event represents an exigent circumstance is supposed to be dependent on the seriousness of the offense of the people involved. This means that the possible crimes that could have been done or were about to carry out would justify as to whether the officers are indeed warranted to go into the house.
A third applicable case would be v. (1989). In this case, the motive or intent of the officers involved in a case breaching a Fourth Amendment right are supposed to be judged in such a way that the actions are believed to be reasonable given the conditions that they are encountering in the said situation. This means that in any case, the actions done of the police officers should be deemed reasonable inherently because they are merely enforcing the law.
IV. Analysis of the Case
The case basically shows nothing tantamount to an exigent circumstance. A teenage kid throwing a punch at a full grown man does not equal to a situation requiring emergency aid. This means that the officers’ entry on the house is not justified. More than that, it is a violation of the Fourth Amendment considering that the intention of the police officers upon coming into the house is basically to arrest individuals, and while doing so, sought to gather the necessary evidence to convict the defendants.
Moreover, the case of v. (1978) indicated the need for serious bodily harm. The situation in the current case did not display anything equivalent to the said description or in any way displayed a threat of serious harm. Similarly, the police officers have not exercised the ‘knock and announce’ rule. According to this rule, the police officers must have to knock at the door and identify themselves before coming into the house. In this case, they have actually come in the vicinity of the house and went to the back yard without even asking permission from the owners of the house. This does present a blatant disregard of the Fourth Amendment.
A more important issue on this case is the protection of privacy of the defendants. Was the entry reasonable under the Fourth Amendment? In the case of v. , (1979), the judge handling the case indicated that the Fourth Amendment essentially imposed the reasonableness of the exercise of discretion of the law enforcement officers. Basically, it is a protection from any unreasonable invasion of privacy. Based on the facts of the case, prior to the US Supreme Court decision, four laws of the State of Utah held that the actions done by the police was an arbitrary invasion of the privacy. This decision by the US Supreme Court has given the law enforcement more teeth in implementing the law. This has given law enforcement the capacity to enter a private property arbitrarily given that they could establish afterwards that there were exigent circumstances that triggered the entry. However, it is still a private property, a dwelling not owned by the government. This means that the occupants of the property have the “right to be let alone.”
( v. ., , [1967]) Thus, the actions of the police officers were inherently a violation of the expected privacy held by the occupants of the house, and therefore a violation of the Fourth Amendment. ( v. ., [1928])
In an article by (2001, ) it claimed that cases like that of Brigham City, Utah v Stuart are not rare in the US. Specifically, he noted that the case law surrounding the implementation of the Fourth Amendment highly revolves around the expectation of privacy among individuals. This indicates that privacy and the Fourth Amendment actually have a rather close connection. He even cites several cases indicating that there are certain areas where an individual have no recourse on the Fourth Amendment. He noted that areas concerning the private individual such as bank records, the telephone numbers that they called, or even from surveillances from helicopters or any other low flying crafts are among the things that the government could consult whenever they feel that a criminal activity may have been taking place. The article even indicated that law enforcement officers are unrestricted to inspect the garbage that people place in the street. This means that privacy could not be expected from these areas. Downright normal things that a private person does from the amount of your bank account, the numbers you’ve dialed, your wastes, and even what you were doing in your backyard, privacy could not be protected.
In the case of Brigham City, Utah v Stuart, it shows that the concept of privacy may have become more of a privilege rather than a right. The government will inevitably be interfering with the dealings of the common man on its pursuit to enforce the law. This is especially true and even became evident right after the terrorist attacks in 2001. The ratification of the Patriot Act has reduced the people’s right to privacy. Authority and power has been given to law enforcement bodies just to combat what has been perceived as a war against terrorism. And how do these actions leave the common man? He/she is subjected to constant monitoring by the government. Security cameras are installed such that any criminal activity may be averted. Though it may have been a great tool for the law enforcement agencies in solving crimes, it has nevertheless significantly taken away some of the privacy rights of the people. Does this mean that the government doesn’t trust the public? Based on the discussions above, one may come to that conclusion.
V. Conclusion
The Fourth Amendment was initially ratified to protect the public from abuse of power. However, the period on which this right has been created battles a situation considerably different to those encountered today. Basically, the case of Brigham City, Utah v Stuart is one of the examples on that difference. The abuse of power and even the mere exercise of discretion by law enforcement officers are separated by a very blurry line. It is thus the role of the courts to make a definite decision on whether police actions are actually out of line or not. To its end, the case presented that the government still trusts its people. The actions of the police officers were an indication of how they want to stop the physical altercation between the individuals. In the same time the courts have provided the defendants the opportunity to defend their side of the story. All in all, people need institutions like the courts to protect their rights from any form of abuse, in the same way it is the commission of the courts to monitor as to whether the public did breach any rule of law.
VI. References
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