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Fourth Amendment--Protective Sweep Doctrine: When Does the Fourth Amendment Allow Police Officers to Search the Home Incident to a Lawful Arrest Mark J

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Fourth Amendment--Protective Sweep Doctrine: When Does the Fourth Amendment Allow Police Officers to Search the Home Incident to a Lawful Arrest Mark J Journal of Criminal Law and Criminology Volume 81 Article 7 Issue 4 Winter Winter 1991 Fourth Amendment--Protective Sweep Doctrine: When Does the Fourth Amendment Allow Police Officers to Search the Home Incident to a Lawful Arrest Mark J. Sifferlen Follow this and additional works at: https://scholarlycommons.law.northwestern.edu/jclc Part of the Criminal Law Commons, Criminology Commons, and the Criminology and Criminal Justice Commons Recommended Citation Mark J. Sifferlen, Fourth Amendment--Protective Sweep Doctrine: When Does the Fourth Amendment Allow Police Officers to Search the Home Incident to a Lawful Arrest, 81 J. Crim. L. & Criminology 862 (1990-1991) This Supreme Court Review is brought to you for free and open access by Northwestern University School of Law Scholarly Commons. It has been accepted for inclusion in Journal of Criminal Law and Criminology by an authorized editor of Northwestern University School of Law Scholarly Commons. 0091-4169/91/8104-862 THE JoURNAL oF CRIMINAL LAW & CRIMINOLOGY Vol. 81, No. 4 Copyright © 1991 by Northwestern University, School of Law Prinled in U.S.A. FOURTH AMENDMENT-PROTECTIVE SWEEP DOCTRINE: WHEN DOES THE FOURTH AMENDMENT ALLOW POLICE OFFICERS TO SEARCH THE HOME INCIDENT TO A LAWFUL ARREST? Maryland v. Buie, 110 S. Ct. 1093 (1990) I. INTRODUCTION In Maryland v. Buie,' the Supreme Court held that the fourth amendment permits an officer executing an arrest warrant in a pri- vate awelling to search rooms other than the room in which the arrest is made, whenever the searching officer possesses a reason- able belief, based on specific and articulable facts, that the adjacent rooms harbor another individual posing a danger to those on the arrest scene. The majority based its approval of this "protective sweep" on the "reasonable suspicion" exception to traditional 2 fourth amendment searches first articulated in Terry v. State of Ohio. The majority thus extended the Terry holding, which permits officers to conduct a protective, warrantless search of a person, to "protec- tive sweeps" conducted by police officers incident to a lawful, in- home arrest.3 Conversely, the Buie dissent argued that the Terry test does not extend to searches of the home and that the fourth amendment war- rant and probable cause requirements should be applied to protec- tive sweeps in private dwellings. 4 The dissent warned that the majority understated the intrusiveness of the search, and reasoned that the majority's holding further would erode traditional fourth amendment protection from warrantless searches of the home.5 This Note examines the evolution of the protective sweep doc- trine and the prior Supreme Court cases which have defined the I 110 S. Ct. 1093 (1990). 2 392 U.S. 1 (1968). 3 Buie, 110 S. Ct. at 1098. 4 Id. at 1103 (Brennan, J., dissenting). 5 Id. at 1102 (Brennan, J., dissenting). 862 1991] FOURTH AMENDMENT-PROTECTIVE SWEEPS 863 right of law enforcement officers to conduct a warrantless search under either exigent circumstances or incident to an arrest. This Note argues that the Buie majority correctly balanced the legitimate concerns of officer safety against the sanctity of the home embodied in the fourth amendment. The Court thus reasonably extended the Terry doctrine to warrantless searches of the home while preserving fourth amendment safeguards against unreasonable search and seizures. This Note argues, however, that while the emphasis on officer safety is appropriate, the majority failed to offer adequate guidance as to the types of "specific and articulable" facts which may outweigh the established fourth amendment protections of the home. When assessing the constitutionality of a protective sweep, this Note suggests that certain factors should be given priority in balancing the concerns of officer safety against the protections of the fourth amendment. II. HISTORY OF THE PROTECTIVE SWEEP DOCTRINE6 Generally, a "protective sweep" is a "quick and limited search of a premises, incident to an arrest and conducted to protect the safety of police officers or others."' 7 The protective sweep is an ex- ception to the fourth amendment mandate that a law enforcement officer have probable cause and a search warrant to conduct a search of an individual's home.8 Courts have developed the "protective sweep" doctrine to allow officers lawfully executing an arrest war- rant to take action to protect themselves when they reasonably fear that confederates of the arrestee might endanger their safety.9 This doctrine emerged in response to the uncertainty regarding the right of law enforcement officers to conduct a search incident to an in- home arrest. Prior to Chimel v. California,10 an officer generally was allowed to 6 See generally Joseph, The ProtectiveSweep Doctrine: ProtectingArresting Officersfrom Attack by Persons Other than the Arrestee, 33 CATH. U.L. REv. 95 (1983) [hereinafter Joseph]; Kelder & Statman, The Protective Sweep Doctrine: Recurrent Questions Regardingthe Propriety of Searches Conducted Contemporaneously with an Arrest on or Near Private Premises, 30 SYRACUSE L. REv. 973 (1979) [hereinafter Kelder]; W. LAFAvE, SEARCH AND SEIZURE § 6.4 (2d ed. 1987) [hereinafter W. LAFAvE]. 7 Buie, 110 S. Ct. at 1094. 8 The fourth amendment to the United States Constitution provides: 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 issue, but upon probable cause, supported by Oath or affirmation, and particu- larly describing the place to be searched, and the persons or things to be seized. U.S. CONsT. amend. IV. 9 State v. Toliver, 5 Wash. App. 321, 324, 487 P.2d 264, 267 (1971). 10 395 U.S. 752 (1969). 864 SUPREME COURT REVIEW [Vol. 81 search throughout the place where an arrest was made to find and seize items connected with the crime.1 1 This right to conduct a war- rantless search incident to a lawful arrest extended to searches far beyond the room in which the arrest was made. 12 Officers generally were allowed to search the entire area considered to be in the "pos- 13 session" or under the "control" of the person arrested. In Chimel, officers went to the arrestee's premises and waited with his wife for the arrestee to return.' 4 Upon the arrival of the arrestee, the officers executed the arrest and then searched the en- tire three bedroom house for evidence. The officers searched the attic, garage and even opened drawers to look for evidence.' 5 The California court upheld the search of the petitioner's entire house under the "possession" and "control" theory. 16 The Chimel Court examined the confused state of the law re- garding the right to conduct a warrantless search of the home, and held that an officer executing an arrest warrant may search the ar- restee's person and any "nearby area" from which he or she might obtain possession of a weapon or destructible evidence. 17 The Court stated, however, that a "comparable justification" did not ex- ist to allow the officers to search any room other than the one in which the arrest occurred.' 8 The Court concluded that the fourth amendment mandates that searches of other rooms or through closed and concealed areas can only be conducted under the author- ity of a search warrant.19 The Chimel Court thus separated the protection rationale, which warranted the search of the arrestee and the area under his or her immediate control, from the desire to obtain evidence, which did not warrant such an intrusive search of the rest of the home. The Court in Chimel acknowledged that this approach was similar to the 20 analysis underlying their previous decision in Terry v. Ohio. In Terry, decided one year before Chimel, the Court replaced the 11 United States v. Rabinowitz, 339 U.S. 56, 61 (1950). 12 See, e.g., Harris v. United States, 331 U.S. 145 (1947) (search of entire four room apartment of a man arrested in his living room approved as "incident to arrest"). 13 Chimel, 395 U.S. at 760. 14 Id. at 753. '5 Id. at 754. 16 Id. at 760. 17 Id. at 763. 18 Id. 19 Id. It is important to remember that the search in Chimel beyond the immediate reach of the arrestee was primarily a search for evidence, not a protective search for potentially dangerous third persons. See infra text accompanying notes 84-87 for a dis- cussion of this important distinction. 20 Id. at 762. 1991] FOURTHAMENDMENT-PROTECTIVE SWEEPS 865 requirement of probable cause for searches and seizures in certain arrest situations with a reasonableness test.21 The Tery Court ex- amined the legality of a street-side, stop-and-frisk search by an of- ficer who, though he had no probable cause to make an arrest, nonetheless suspected that the individual under surveillance was armed and dangerous.22 The Court held that if a police officer rea- sonably concludes from the facts present that the person with whom he or she is dealing is dangerous, then the officer can conduct a carefully limited search of the person to look for weapons that may be used against the officer.23 The Terry Court limited the scope of this exception to the fourth amendment's warrant and probable cause requirements by declaring a two-pronged reasonableness test; specifically, the of- ficer's intrusion must be: (1) justified at its inception; and (2) rea- sonably related in scope to the circumstances which justified the 24 initial action. Applying this dual inquiry, the Terry Court first held that an of- ficer must be able to point to "specific and articulable facts" which, together with the rational inferences from those facts would justify the officer's intrusion.
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