People v. Knapp, 52 N.Y.2d 689 (1981)
A warrantless search of a home is per se unreasonable unless it falls within a recognized exception, and the burden of proving such an exception rests on the government; the “exigent circumstances” exception requires a showing of urgent events making it impossible to obtain a warrant in time to preserve evidence, and this exception is strictly limited by the necessities of the situation.
Summary
Warren Knapp was convicted of drug possession and sale. The police, using an informant, arranged a controlled buy at Knapp’s home. After arresting Knapp, the police conducted a warrantless search of his bedroom and basement, seizing additional drugs and lab equipment. The New York Court of Appeals held that the initial seizure in the kitchen was lawful as a search incident to arrest. However, the subsequent searches of the bedroom and basement were unconstitutional because they were not justified by exigent circumstances, plain view, inevitable discovery, or harmless error. The Court emphasized the heightened protection afforded to homes under the Fourth Amendment and the necessity of obtaining a warrant absent a true emergency.
Facts
Frederick Botway, a police informant, assisted Warren Knapp in manufacturing methaqualone in Knapp’s basement. Knapp planned to sell the drugs. Botway informed Detective Sievers, who arranged a controlled buy. Sievers and Botway arrived at Knapp’s home, where Knapp showed them two plates of drugs in the kitchen. Knapp mentioned more drugs and capsules were in his bedroom. Sievers signaled other officers, who entered and arrested Knapp. After securing the house, officers searched Knapp’s bedroom and seized additional drugs. A later search of the basement, about an hour after the arrest, revealed a drug lab.
Procedural History
Knapp was convicted in County Court after his motion to suppress the evidence seized from his home was denied. The Appellate Division affirmed the conviction. Knapp appealed to the New York Court of Appeals, arguing that the warrantless searches violated his constitutional rights. The Court of Appeals granted leave to appeal.
Issue(s)
1. Whether the warrantless search of Knapp’s kitchen was justified as a search incident to a lawful arrest?
2. Whether the warrantless search of Knapp’s bedroom and basement was justified by exigent circumstances, plain view, inevitable discovery, or harmless error?
Holding
1. Yes, because the kitchen search was a limited search of the area within Knapp’s immediate control during a lawful arrest.
2. No, because there were no exigent circumstances justifying the warrantless searches of the bedroom and basement, and the plain view, inevitable discovery, and harmless error doctrines do not apply.
Court’s Reasoning
The Court reasoned that the kitchen search was permissible under the search-incident-to-arrest exception, allowing a limited search of the arrestee’s person and the area within their immediate control to prevent resistance or destruction of evidence, citing Chimel v. California, 395 U.S. 752 (1969). However, the Court found the subsequent searches of the bedroom and basement unconstitutional. The Court emphasized the strong protection afforded to homes under the Fourth Amendment, stating that “a warrantless search of an individual’s home is per se unreasonable and hence unconstitutional.”
The Court rejected the “exigent circumstances” argument because the police had ample time to obtain a warrant before the arrest, and there was no immediate threat of destruction of evidence after Knapp was secured. The Court noted, “before the police here undertook their search of either the bedroom or the basement, it is clear that any urgency was gone.”
The “plain view” exception was inapplicable because the warrantless entry into the bedroom and basement was not justified. The “inevitable discovery” doctrine also failed because the People did not demonstrate an independent means of obtaining the evidence. The Court stated, “Were the rule otherwise, every warrant-less nonexigent seizure automatically would be legitimatized by assuming the hypothetical alternative that a warrant had been obtained.”
Finally, the Court concluded that the admission of the illegally seized evidence was not harmless error, as the jury’s initial deadlock suggested that the evidence may have contributed to Knapp’s conviction.