The Broken Door

New York detectives spent two days building probable cause to believe the Defendant had murdered a gas station manager on January 13, 1970. Six officers arrived at his Bronx apartment at 7:30 a.m. on January 15 with probable cause to arrest him for murder but without an arrest warrant. Light and music came from inside, but no one answered the officers' knock. After summoning emergency assistance and waiting roughly thirty minutes, the officers forced the apartment door open with crowbars and entered. The Defendant was not home. In plain view inside, officers found a .30-caliber shell casing, which they seized; it was later introduced as evidence at the Defendant's murder trial. The Defendant eventually surrendered to police and was indicted for murder. At issue is whether officers who have probable cause to believe a person committed a felony may, without first obtaining an arrest warrant, force their way into that person's home to make a routine arrest.