Simone Lawson
Kentucky v. King is a 2011 United States Supreme Court case that addressed the constitutionality of warrantless searches. The case centred on a mistaken drug investigation in Lexington, Kentucky, where police officers pursued a suspect to an apartment complex. The officers knocked on the door and announced their presence, causing the occupants to attempt to destroy evidence. The Supreme Court ruled that police may conduct a warrantless search under the exigent circumstances exception if they have cause to believe evidence is being destroyed, as long as they do not violate the Fourth Amendment. This decision reshaped police search powers and the legal landscape surrounding warrantless searches, reaffirming the importance of balancing effective policing with constitutional rights.
| Characteristics | Values |
|---|---|
| Date | May 16, 2011 |
| Decision | The Supreme Court ruled that police may conduct a warrantless search under the exigent circumstances exception, even if their lawful actions (such as knocking and announcing their presence) lead to those circumstances, so long as they do not violate or threaten to violate the Fourth Amendment. |
| Exigent circumstances exception | The imminent destruction of evidence |
| Police-created exigency doctrine | The police may not rely on the need to prevent the destruction of evidence when the exigency was created by the police in the first place. |
| Lower courts | Lower courts responded to this reality by creating the police-created exigency doctrine, which provides that the police may not rely on the need to prevent the destruction of evidence when the exigency was created by the police. |
| Supreme Court of Kentucky decision | The Supreme Court of Kentucky reversed the lower court's order, finding that the entry was improper. |
| Kentucky Court of Appeals decision | The Kentucky Court of Appeals affirmed the conviction, holding that exigent circumstances supported the warrantless search and were not of the police's making. |
| Fayette Circuit Court decision | The Fayette Circuit Court denied the motion to suppress the evidence from the warrantless search. |
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What You'll Learn
The exigent circumstances exception
The Court held that the exigent circumstances rule applies when the police did not create the exigency by engaging or threatening to engage in conduct that violated the Fourth Amendment. This decision clarified that police may conduct a warrantless search under the exigent circumstances exception, even if their lawful actions (such as knocking and announcing their presence) lead to those circumstances, as long as they do not violate or threaten to violate the Fourth Amendment.
The Court's decision in Kentucky v. King provided law enforcement with clearer guidance while reaffirming the importance of the Fourth Amendment's core protections. It established that lawful police conduct does not preclude the application of the exception. The Court reasoned that when a police officer knocks on a door without a warrant, they are doing no more than any other citizen in that situation. The occupants of the home choose whether to address the person at the door, and if they choose to destroy evidence, they have only themselves to blame for a warrantless entry that follows.
However, the Court's decision in Kentucky v. King was not without controversy. Justice Ginsburg, as the lone dissenter, forcefully disagreed, writing that the majority's decision arms the police with a simple way to circumvent the Fourth Amendment's warrant requirement in drug cases. The decision has been criticised for dishonouring the warrant requirement and creating a precedent that may be used to justify warrantless searches.
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The police-created exigency doctrine
The "police-created exigency" doctrine is a legal concept that was central to the Kentucky v. King case. This doctrine holds that police officers cannot rely on exigent circumstances—such as the destruction of evidence—to justify a warrantless search if their own conduct created the exigency in the first place. In other words, the police cannot manufacture emergencies as a pretext to circumvent the Fourth Amendment's warrant requirement.
Prior to the Kentucky v. King case, lower courts had applied this doctrine in situations where police conduct appeared to create the urgency that justified a warrantless entry. However, the exact contours of what constituted "creating" an exigency were unclear, leading to inconsistent rulings across jurisdictions.
In Kentucky v. King, the U.S. Supreme Court addressed the question of whether the police-created exigency doctrine applied when officers, by knocking on the door of a residence and announcing their presence, caused the occupants to attempt to destroy evidence. The Court ruled that the exigent circumstances rule could still be invoked, even if the police conduct led to those circumstances, as long as the police did not violate or threaten to violate the Fourth Amendment prior to the warrantless entry.
The Court's decision in Kentucky v. King provided valuable guidance to law enforcement officers by clarifying the circumstances under which they could lawfully conduct a warrantless search. The Court rejected the application of the police-created exigency doctrine in this case, holding that the focus should be on whether the police conduct was objectively reasonable and did not violate the Fourth Amendment, rather than on the subjective motivations of the officers.
The Supreme Court's ruling in Kentucky v. King has had a significant impact on law enforcement practices and Fourth Amendment litigation across the United States. It has reshaped the legal landscape surrounding warrantless searches and the exigent circumstances exception, providing clearer guidance to law enforcement while reaffirming the importance of protecting individual rights.
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The Fourth Amendment
> "The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall be issued without probable cause."
In the case of Kentucky v. King, the U.S. Supreme Court addressed the question of whether police officers can enter a home without a warrant if their presence causes the occupants to destroy evidence. The Court ruled that police may conduct a warrantless search under the exigent circumstances exception, provided they do not violate or threaten to violate the Fourth Amendment. This decision clarified that lawful police conduct does not preclude the application of the exception.
The Supreme Court's ruling in Kentucky v. King redefined the boundaries of the exigent circumstances exception, particularly in situations where police conduct might appear to create the urgency justifying a warrantless entry. The case arose from a mistaken drug investigation in Lexington, Kentucky, and its outcome has significantly impacted law enforcement practices and Fourth Amendment litigation across the United States.
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The destruction of evidence
In Kentucky v. King, the U.S. Supreme Court addressed the question of whether the warrantless search rule applies when the police, by knocking on the door of a home and announcing their presence, cause the occupants to destroy evidence. The case arose in Lexington, Kentucky, where police officers set up a controlled purchase of crack cocaine near an apartment complex. After the transaction, the police moved in on the buyer, who quickly entered an apartment. Uncertain which apartment the suspect had entered, officers smelled marijuana outside one door and decided to investigate further. They knocked on the door and announced their presence. As soon as they began knocking, they heard noises coming from the apartment, which they believed indicated that the occupants were destroying evidence.
The Fourth Amendment requires that police obtain a warrant before entering a home, though there are some exceptions. One exception involves a situation in which evidence of a crime is being destroyed. The imminent destruction of evidence exigency, however, creates the problem that the police may create a situation that will lead a suspect to attempt to destroy evidence, thus enabling them to make a warrantless entry into a home. Lower courts responded to this reality by creating the police-created exigency doctrine, which provides that the police may not rely on the need to prevent the destruction of evidence when they created the exigency in the first place.
In Kentucky v. King, the Court articulated the new rule that the destruction of evidence as an exigent circumstance justifies a warrantless search when the conduct of the police preceding the exigency is reasonable, meaning that the police did not gain entry to the premises by means of an actual or threatened violation of the Fourth Amendment. The Court reasoned that when a police officer knocks on a door without a warrant, they are doing no more than any other citizen in that situation. The occupants of the home choose whether to address the person at the door, and if they choose not to, the police will likely move on from their investigation. Occupants who choose to destroy evidence instead have only themselves to blame for a warrantless entry that follows.
The Court held that the exigent circumstances rule applied when the police did not create the exigency by engaging or threatening to engage in conduct that violated the Fourth Amendment. The Court also held that, assuming an exigency existed in this case, there was no evidence that the officers either violated the Fourth Amendment or threatened to do so before they entered the apartment. Therefore, the Court reversed and remanded for further proceedings. The Supreme Court of Kentucky had previously reversed the lower court's decision, reasoning that the police impermissibly created the basis for the exigent circumstances.
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The Supreme Court's ruling
In Kentucky v. King, the U.S. Supreme Court addressed the question of whether police may conduct a warrantless search of a home if, by knocking on the door and announcing their presence, they cause the occupants to destroy evidence.
The Court ruled that police may conduct a warrantless search of a home under the exigent circumstances exception if they have cause to believe that the occupants are engaged in the destruction of evidence, as long as the police did not violate or threaten to violate the Fourth Amendment before the search. This decision clarified that lawful police conduct does not preclude the application of the exception. The ruling redefined the boundaries of the exigent circumstances exception, particularly in situations where police conduct might appear to manufacture the urgency justifying a warrantless entry.
The Court articulated a new rule that the destruction of evidence as an exigent circumstance justifies a warrantless search when the police conduct preceding the exigency is reasonable. This means that the police did not gain entry to the premises by violating or threatening to violate the Fourth Amendment. The Court reasoned that when a police officer knocks on a door without a warrant, they are doing no more than any other citizen in that situation. The occupants of the home choose whether to address the person at the door, and if they choose to destroy evidence instead, they have only themselves to blame for the subsequent warrantless entry.
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Frequently asked questions
The case arose from a mistaken pursuit during a drug investigation in Lexington, Kentucky, and addressed the question of whether the police can enter a home without a warrant if they believe the occupants are destroying evidence.
The Supreme Court ruled that police may make a warrantless entry into a home where they have cause to believe that the occupants are engaged in the destruction of evidence, as long as they did not violate the Fourth Amendment or threaten to do so before entering the home.
The ruling redefined the boundaries of the exigent circumstances exception, providing clearer guidance to law enforcement while reaffirming the importance of the Fourth Amendment's protections. It also rejected the "police-created exigency" doctrine, which was intended to prevent law enforcement from manufacturing emergencies to bypass the Fourth Amendment.
Justice Ruth Bader Ginsburg, in her dissenting opinion, contended that the ruling allowed police to "dishonor the Fourth Amendment's warrant requirement in drug cases." She argued that the exigency must exist when the police arrive and should not be created by their own conduct, raising concerns about the potential for law enforcement to circumvent the warrant requirement.
