Lange v. California

In Lange v. California, Arthur Gregory Lange was driving in Sonoma County, California, while playing loud music and honking his horn. A California Highway Patrol officer, Aaron Weikert, began following him and activated his lights. Lange turned into his driveway and entered his attached garage. The officer followed him into the garage without a warrant and arrested him for driving under the influence. Lange moved to suppress evidence, arguing the warrantless entry violated the Fourth Amendment. California courts upheld the entry under the "hot pursuit" exception for misdemeanors. The U.S. Supreme Court granted certiorari to decide whether the exigent circumstances doctrine allows police to enter a home without a warrant when pursuing a fleeing misdemeanor suspect. The case was argued and decided on June 23, 2021.

The Supreme Court unanimously reversed the California Court of Appeal, holding that the hot pursuit of a fleeing misdemeanor suspect does not categorically justify a warrantless entry into a home. The case was remanded for a totality-of-the-circumstances analysis.

Whether the Fourth Amendment permits warrantless entry into a home when police are in hot pursuit of a person suspected of a misdemeanor, or whether such entry requires a case-specific showing of exigent circumstances beyond the mere fact of pursuit.

The decision reinforced Fourth Amendment protections for the home by limiting the scope of the exigent circumstances exception in misdemeanor cases. It requires police to justify warrantless entries based on specific facts, potentially affecting law enforcement practices nationwide and strengthening privacy rights against searches for minor offenses.