Implications of Kentucky v. King

Kentucky v. King

Case: Kentucky v. King (2011)

Facts: In Lexington, Kentucky the police were following someone who they believed was a known crack dealer into an apartment complex. Outside of the apartment door, they smelled marijuana smoke. The officers knocked on the door and announced their presence. After this occurred, they heard the people inside moving around. This sounded like they were in the process of trying to destroy evidence. The police subsequently, stated their intention to enter the apartment and kicked in the door. When they entered the apartment, they seen other people and the drugs in plain sight. After conducting a protective sweep, they found even more drugs and paraphernalia. During the trial, the defendants tried to have the evidence sequestered under the case precedent established by under Mapp v. Ohio. It states that when there is the improper search of a private residence, any evidence collected against the suspects is automatically thrown out under the poisonous tree doctrine. In the case, the defendants felt that since the police did not have a search warrant, the search was illegal. This meant they should not be able to use any evidence against them, based upon the fact that they were perusing someone else and arrested others who were not under investigation. Instead, they were in the wrong place at the wrong time. These individuals were convicted and appealed the decision to Circuit Court. They found that the police acted properly based upon the fact that exigent circumstances required them to move quickly in order to prevent evidence from being destroyed. The Kentucky Supreme Court reversed the decision. This is because the police should have known that the defendants would have engaged in these actions as they were surprised by their presence. They felt that this was a natural reaction, when law enforcement comes knocking and forces their way in.

Issue: The U.S. Supreme Court is looking at when exigent circumstances apply and what standards must be utilized in these kinds of circumstances.

Holding: In an 8 to 1 decision, the court found that the actions taken by the police were legal. This is because they did not create the exigent circumstances. Instead, it was the crack dealer who allowed this to occur, when he went inside the apartment in order to evade them. This meant that they could use this as justification for entering the residence.

Majority Reasoning: (Alito) The majority of the Justices had several different reasons for supporting their decision. The most notable include: when the exigent rule applies and how it is interpreted in conjunction with the Fourth Amendment.

Rule A: The exigent rule applies, as the court determined that all searches and seizures must be reasonable. This based upon previous case precedent established under Brigham City v. Stuart and Mincey v. Arizona. Brigham City v. Stuart found that warrantless searches are legal when there is the possibility that evidence could be destroyed and the police need to act quickly to prevent this (i.e. exigent circumstance). Mincey v. Arizona confirmed the decision by illustrating the significance of this doctrine, in order to preserve evidence during the course of conducting an investigation. This takes place, with law enforcement feeling that there is the likelihood evidence will be destroyed during the process of obtaining a warrant to search the premise. In these circumstances, they have the right to conduct a warrantless raid in order to achieve these objectives. The Supreme Court found that the circumstances in Kentucky v. King allowed them to kick in the door and search the premise as reasonable circumstances exist.

Rule B: The way these practices are interpreted, in contrast with the Fourth Amendment, occurred when the police can seize evidence in plain sight. This is based upon the decision from Horton v. California. In these situations, the Fourth Amendment is not violated when the evidence is in open view. The situation with Kentucky v. King, is following these guidelines as the defendants had drugs on the table inside the apartment. This meant that they did not conduct an illegal search and seizure using this case as precedent.

Application: As a result, the police can conduct a search of a residence if there is a logical reason to believe that evidence is being destroyed when a crime is committed. Anything that is collected in plain sight, is not subject the standards outlined in the Fourth Amendment. Kentucky v. King is illustrating the way this occurred, with the crack dealer running into the apartment to evade them. The fact that he chose to do this, means that that the doctrine of exigent circumstances applies.