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Lange v. California

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Supreme Court of the United States
Lange v. California
Term: 2020
Important Dates
Argument: February 24, 2021
Decided: June 23, 2021
Outcome
Vacated and remanded
Vote
9-0
Majority
Elena Kagan • Stephen Breyer • Sonia Sotomayor • Neil Gorsuch • Amy Coney Barrett
Concurring
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Brett Kavanaugh

Lange v. California is a case argued before the Supreme Court of the United States on February 24, 2021, during the court's October 2020-2021 term.

In a unanimous ruling, the U.S. Supreme Court vacated the California First District Court of Appeal's ruling and remanded the case for further proceedings, holding that under the Fourth Amendment, the pursuit of a fleeing misdemeanor suspect does not always or categorically justify a warrantless entry into a home. Justice Elena Kagan authored the court's majority opinion. Chief Justice John Roberts filed a concurring opinion, joined by Justice Samuel Alito. Justice Clarence Thomas filed an opinion concurring in part and concurring in the judgment, joined by Justice Brett Kavanaugh. Justice Kavanaugh also filed a concurring opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Arthur Lange was driving home on the highway in Sonoma, California. California highway patrol officer Aaron Weikert pursued Lange with the intention of conducting a traffic stop. Weikert followed Lange home and activated his overhead lights once Lange pulled into his home's driveway. Lange pulled into his garage and the garage door began closing behind him. Weikert approached Lange and stopped the garage from closing with his foot. He questioned Lange and asked if Lange knew Weikert was following him. Lange stated that he did not know Weikert was following him. Weikert stated he smelled alcohol on Lange's breath and charged Lange with driving under the influence. At trial, Lange claimed that Weikert's entry into Lange's home violated the Fourth Amendment since Weikert did not have a warrant to enter Lange's home, and moved to suppress a video recording of the incident. The trial court concluded that the officer had probable cause, denied the motion to suppress, and issued a conviction for Lange. Later, a civil court ruled that Lange's arrest was unlawful and an appellate court ruled that the arrest was lawful. On appeal to the California First District Court of Appeal, the court affirmed the conviction. Click here to learn more about the case's background.
  • The questions presented: "Whether the pursuit of a person whom a police officer has probable cause to believe has committed a misdemeanor categorically qualifies as an exigent circumstance sufficient to allow the officer to enter a home without a warrant."[2]
  • The outcome: The U.S. Supreme Court vacated the California First District Court of Appeal's ruling and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the California First District Court of Appeal. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    • June 23, 2021: The U.S. Supreme Court vacated the California First District Court of Appeal's ruling and remanded the case for further proceedings.
    • February 24, 2021: The U.S. Supreme Court heard oral argument.
    • October 19, 2020: The U.S. Supreme Court agreed to hear the case.
    • July 10, 2020: Arthur Lange appealed to the U.S. Supreme Court.
    • October 30, 2019: The California First District Court of Appeal affirmed the trial court's judgment of conviction.

    Background

    In October 2016, Arthur Lange was driving home on the highway in Sonoma, California. While driving, Lange was listening to loud music and honked his horn a few times. California highway patrol officer Aaron Weikert pursued Lange with the intention of conducting a traffic stop and did not activate his siren or overhead lights. Weikert stated later that he believed the volume of the music and the honking of the horn was in violation of the California Vehicle Code. Weikert followed Lange home. Lange neared his driveway and Weikert activated his overhead lights. Lange pulled into his garage and the garage door began to close behind him. Weikert parked in Lange's driveway, approached Lange, stopped the garage door from closing with his foot, and entered Lange's garage. Weikert questioned Lange, asking if he had seen Weikert following behind him and the overhead lights. Lange said that he did not. Weikert stated that he smelled alcohol on Lange's breath. He ordered Lange out of the garage and charged Lange with a misdemeanor offense of driving under the influence.[3][4]

    At trial, Lange argued that Weikert's entry into Lange's garage without a warrant was a violation of the Fourth Amendment to the United States Constitution and therefore the evidence Weikert obtained at that time should not be considered in the proceedings. Lange moved to suppress a video recording of the incident from consideration as evidence at trial. The prosecutor argued that Lange committed a misdemeanor when he failed to stop after Weikert activated the overhead lights and as a result, Weikert had probable cause to arrest Lange and was justified in entering Lange's garage without a warrant. The court denied Lange's motion to suppress. In January 2017, Lange was charged with two misdemeanor violations of driving under the influence of alcohol and with the infraction of operating a vehicle's sound system at excessive levels. Later, the prosecutor added an allegation that Lange had a prior conviction for driving under the influence.[3][4]

    Based on the incident, the Department of Motor Vehicles suspended Lange's driver's license for one year. Lange filed a petition to overturn the suspension in civil court. In January 2018, the civil court granted Lange's petition and concluded that Lange's arrest was unlawful.[3][4]

    Also in January 2018, the appellate division of the Superior Court of Sonoma County affirmed the trial court's denial of Lange's motion to suppress, concluding that Weikert had probable cause to believe Lange's intention was to evade detention and that Weikert's entry into Lange's garage was lawful. Lange pleaded no contest to the misdemeanor offense of driving under the influence of alcohol. He appealed the trial court's decision to deny his suppression motion. The state moved to dismiss Lange's second appeal. In November 2018, the court denied the motion to dismiss. In March 2019, the superior court affirmed Lange's conviction, concluding that there was probable cause to believe Lange intended to evade detention and that Weikert's entry into Lange's garage was lawful.[3][4]

    In April 2019, Lange petitioned the California First District Court of Appeal for a transfer of his case to the court. The court granted the petition. On appeal, the First District Court of Appeal affirmed Lange's conviction. In July 2020, Lange petitioned the Supreme Court of the United States for review. On October 19, 2020, the Supreme Court granted review of the case.[3]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    • "Whether the pursuit of a person whom a police officer has probable cause to believe has committed a misdemeanor categorically qualifies as an exigent circumstance sufficient to allow the officer to enter a home without a warrant."

    Oral argument

    Audio

    Audio of oral argument:[5]



    Transcript

    Outcome

    In a unanimous ruling, the U.S. Supreme Court vacated the California First District Court of Appeal's ruling and remanded the case for further proceedings, holding that under the Fourth Amendment, pursuit of a fleeing misdemeanor suspect does not categorically justify a warrantless entry into a home. Justice Elena Kagan authored the court's majority opinion. Chief Justice John Roberts filed a concurring opinion, joined by Justice Samuel Alito. Justice Clarence Thomas filed an opinion concurring in part and concurring in the judgment, joined by Justice Brett Kavanaugh. Justice Kavanaugh also filed a concurring opinion.[1]

    Opinion

    In the court's majority opinion, Justice Elena Kagan wrote:[1]

    “ The Fourth Amendment ordinarily requires that police officers get a warrant before entering a home without permission. But an officer may make a warrantless entry when “the exigencies of the situation” create a compelling law enforcement need. Kentucky v. King, 563 U.S. 452, 460 (2011). The question presented here is whether the pursuit of a fleeing misdemeanor suspect always—or more legally put, categorically—qualifies as an exigent circumstance. We hold it does not. A great many misdemeanor pursuits involve exigencies allowing warrantless entry. But whether a given one does so turns on the particular facts of the case.


    ... The flight of a suspected misdemeanant does not always justify a warrantless entry into a home. An officer must consider all the circumstances in a pursuit case to determine whether there is a law enforcement emergency. On many occasions, the officer will have good reason to enter—to prevent imminent harms of violence, destruction of evidence, or escape from the home. But when the officer has time to get a warrant, he must do so—even though the misdemeanant fled.

    Because the California Court of Appeal applied the categorical rule we reject today, we vacate its judgment and remand the case for further proceedings not inconsistent with this opinion.[6]

    		”
    —Justice Elena Kagan

    Concurring opinion

    Chief Justice Roberts

    Chief Justice John Roberts filed a concurring opinion, joined by Justice Samuel Alito.[1]

    In his concurring opinion, Chief Justice Roberts wrote:

    “ Suppose a police officer on patrol responds to a report of a man assaulting a teenager. Arriving at the scene, the officer sees the teenager vainly trying to ward off the assailant. The officer attempts to place the assailant under arrest, but he takes off on foot. He leads the officer on a chase over several blocks as the officer yells for him to stop. With the officer closing in, the suspect leaps over a fence and then stands on a home’s front yard. He claims it’s his home and tells the officer to stay away. What is the officer to do?


    The Fourth Amendment and our precedent—not to mention common sense—provide a clear answer: The officer can enter the property to complete the arrest he lawfully initiated outside it. But the Court today has a different take. Holding that flight, on its own, can never justify a warrantless entry into a home (including its curtilage), the Court requires that the officer: (1) stop and consider whether the suspect—if apprehended—would be charged with a misdemeanor or a felony, and (2) tally up other “exigencies” that might be present or arise, ante, at 1, 4, before (3) deciding whether he can complete the arrest or must instead seek a warrant—one that, in all likelihood, will not arrive for hours. Meanwhile, the suspect may stroll into the home and then dash out the back door. Or, for all the officer knows, get a gun and take aim from inside.

    The Constitution does not demand this absurd and dangerous result. We should not impose it. As our precedent makes clear, hot pursuit is not merely a setting in which other exigent circumstances justifying warrantless entry might emerge. It is itself an exigent circumstance. And we have never held that whether an officer may enter a home to complete an arrest turns on what the fleeing individual was suspected of doing before he took off, let alone whether that offense would later be charged as a misdemeanor or felony. It is the flight, not the underlying offense, that has always been understood to justify the general rule: “Police officers may enter premises without a warrant when they are in hot pursuit of a fleeing suspect.” Kentucky v. King, 563 U.S. 452, 460 (2011). The Court errs by departing from that well-established rule.

    ... Recall the assault we started with. The officer was closing in on the suspect when he hopped the fence and stopped in a yard. The officer starts to climb over the fence to arrest him, but wait—was the assault a misdemeanor or a felony? In Lange’s State of California, it could have been either depending on the identity of the victim, the amount of force used, and whether there was a weapon involved. See Cal. Penal Code Ann. §245 (West 2014). How much force was the man using against the teenager? Is this really the assailant's home in the first place? Pretty suspicious that he jumped the fence just as the officer was about to grab him. If it is his home, are there people inside and, if so, how many? And why would the man run from a mere fight—does he have something more serious to hide?

    By this time, of course, the assailant has probably gone out the back door or down the fire escape and is blocks away, with the officer unable to give a useful description—except for how he looks from behind.[6]

    		”
    —Chief Justice John Roberts

    Justice Thomas

    Justice Clarence Thomas filed an opinion concurring in part and concurring in the judgment, joined by Justice Brett Kavanaugh.[1]

    In his concurring opinion, Justice Thomas wrote:

    “ I join the majority opinion, except for Part II–A, which correctly rejects the argument that suspicion that a person committed any crime justifies warrantless entry into a home in hot pursuit of that person. I write separately to note two things: the general case-by-case rule that the Court announces today is subject to historical, categorical exceptions; and under our precedent, the federal exclusionary rule does not apply to evidence discovered in the course of pursuing a fleeing suspect.


    ... I join the relevant parts of the majority on the understanding that its general case-by-case rule does not foreclose historical, categorical exceptions. Although the majority unnecessarily leads with doctrine before history, it does not disturb our regular rule that history—not court-created standards of reasonableness—dictates the outcome whenever it provides an answer. See, e.g., Wilson v. Arkansas, 514 U. S. 927, 931 (1995); Virginia v. Moore, 553 U.S. 164, 171 (2008).

    I also join on the understanding that the majority has not sought to settle the contours of any of these historical exceptions.

    I also write to point out that even if the state courts on remand conclude that the officer’s entry here was unlawful, the federal exclusionary rule does not require suppressing any evidence.

    ... Aware of the substantial costs created by the exclusionary rule, courts have sometimes narrowed the protections historically afforded by the Fourth Amendment to avoid having to exclude evidence. See Collins v. Virginia, 584 U.S. ___, ___ (2018) (THOMAS, J., concurring) (slip op., at 1); A. Amar, The Constitution and Criminal Procedure: First Principles 30 (1997) (“Judges do not like excluding bloody knives, so they distort doctrine”). But it should be the judicially created remedy, not the Fourth Amendment, that contracts in the face of that pressure. Courts should follow the plain dictates of our precedent: Officers cannot chase a fleeing person into a home simply because that person is suspected of having committed any misdemeanor, but if the officer nonetheless does so, exclusion under the Fourth Amendment is improper. Criminal defendants must rely on other remedies.[6]

    		”
    —Justice Clarence Thomas

    Justice Kavanaugh

    Justice Brett Kavanaugh filed a concurring opinion.[1]

    In his concurring opinion, Justice Kavanaugh wrote:

    “ The Court holds that an officer may make a warrantless entry into a home when pursuing a fleeing misdemeanant if an exigent circumstance is also present—for example, when there is a risk of escape, destruction of evidence, or harm to others. I join the Court’s opinion. I also join Part II of JUSTICE THOMAS’s concurrence regarding how the exclusionary rule should apply to hot pursuit cases.


    I add this brief concurrence simply to underscore that, in my view, there is almost no daylight in practice between the Court’s opinion and THE CHIEF JUSTICE’s opinion concurring in the judgment.

    In his thoughtful opinion, THE CHIEF JUSTICE concludes that pursuit of a fleeing misdemeanant should itself constitute an exigent circumstance. The Court disagrees. As I see it, however, the difference between THE CHIEF JUSTICE’s approach and the Court’s approach will be academic in most cases. That is because cases of fleeing misdemeanants will almost always also involve a recognized exigent circumstance—such as a risk of escape, destruction of evidence, or harm to others—will still justify warrantless entry into a home. See ante, at 1, 4, 16; see also, e.g., City and County of San Francisco v. Sheehan, 575 U.S. 600, 612 (2015); Kentucky v. King, 563 U.S. 452, 460 (2011); Brigham City v. Stuart, 547 U.S. 398, 403 (2006); Minnesota v. Olson, 495 U.S. 91, 100 (1990). As Lange’s able counsel forthrightly acknowledged at oral argument, the approach adopted by the Court today will still allow the police to make a warrantless entry into a home “nine times out of 10 or more” in cases involving pursuit of a fleeing misdemeanant. Tr. of Oral Arg. 34.

    Importantly, moreover, the Court’s opinion does not disturb the long-settled rule that pursuit of a fleeing felon is itself an exigent circumstance justifying warrantless entry into a home. See United States v. Santana, 427 U.S. 38, 42–43 (1976); cf. Stanton v. Sims, 571 U.S. 3, 8, 9 (2013) (per curiam). In other words, the police may make a warrantless entry into the home of a fleeing felon regardless of whether other exigent circumstances are present.

    With those observations, I join the Court’s opinion.[6]

    		”
    —Justice Brett Kavanaugh

    Text of the opinion

    Read the full opinion here.

    October term 2020-2021

    See also: Supreme Court cases, October term 2020-2021

    The Supreme Court began hearing cases for the term on October 5, 2020. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]

    The court issued 67 opinions during its 2020-2021 term. Two cases were decided in one consolidated opinion. Ten cases were decided without argument. Click here for more information on the court's opinions.

    The court agreed to hear 62 cases during its 2020-2021 term. Of those, 12 were originally scheduled for the 2019-2020 term but were delayed due to the coronavirus pandemic. Five cases were removed from the argument calendar.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 U.S. Supreme Court, Lange v. California, decided June 23, 2021
    2. ↑ 2.0 2.1 Supreme Court of the United States, "Questions presented," October 19, 2020
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 California First District Court of Appeal, People v. Lange, decided October 30, 2019
    4. ↑ 4.0 4.1 4.2 4.3 Supreme Court of the United States, "Lange v. California Petition for a writ of certiorari," July 10, 2020
    5. ↑ U.S. Supreme Court, "Oral Argument - Audio, Lange v. California," accessed February 24, 2021
    6. ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ SupremeCourt.gov, "A Brief Overview of the Supreme Court," accessed April 20, 2015
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