Miller v. United States

Miller v. United States, 357 U.S. 301 (1958), was a landmark decision by the United States Supreme Court, which held that one could not lawfully be arrested in one's home by officers breaking in without first giving one notice of their authority and purpose.
Background.
At 1:35 a.m., on March 25, 1955, Federal Bureau of Narcotics agents, serving an arrest warrant, arrested a heroin user, Clifford Reed, on a public street in Washington, DC, for various offences related to narcotics. While in custody, Reed informed federal narcotics agents that he had purchased 100 capsules of morphine from a drug dealer, Arthur R. Shepherd, via a middleman, William Miller, who was 17 years old at the time. Miller had had several run-ins with the law and had been convicted of a narcotics offence in 1953. Reed told agents that he was to meet Shepherd in the later morning hours to make another purchase. The agents then enlisted Reed to aid in the capture of Miller and Shepherd.
Later, at about 3:00 a.m., an undercover agent carrying $100 in marked currency went to Shepherd's home with Reed by taxicab. Reed introduced the agent to Shepherd as a buyer. The agent gave Shepherd the money, and Shepherd promised that another 100 capsules would be procured from Miller and delivered to the agent's home. Shepherd went by taxi to Miller's apartment. The taxi was monitored by federal agents, along with Washington D.C. Metropolitan Police officers. Shepherd got out of the taxi and went into the apartment, which Miller shared with a woman, Bessie Byrd, who was involved in the operation. He entered the basement to remove the drugs from storage, but federal agents could not observe him there. A few minutes later, he came out of the basement and re-entered the cab.
Shepherd was going back to Reed's apartment when the police officers pulled the car over, and he was then arrested and searched. The currency that was given to him by the agent was not found on his person, but he admitted to the officers that the 100 capsules of morphine found on the passenger seat were put there by him after the cab was pulled over. He claimed that the package of capsules was behind a fire extinguisher in the basement hallway, where he was sent by a "fellow" with Reed, who had promised him $10 for retrieving it.
The federal agents and police then returned to Miller's apartment. At about 3:45, they knocked on the door, and a low voice was heard, saying, "Who's there?" The reply was "Police." Miller opened the door, leaving the door chain on and asked what their purpose was. When the agent and officer did not respond, he attempted to close the door. According to the officer, "He took one look at me and tried to slam the door, at which time I grabbed the door and opened it. We put our hands inside the door and pulled and ripped the chain off." They did not have a search warrant or an arrest warrant, and they did not demand admission into the home or express their purpose. Miller was not arrested until they entered his apartment. Bessie Byrd was arrested, and $34 of the money that Shepherd had been given was found on her person. During a search of the apartment, the remaining $66 was found, part in a hatbox in the closet and part under the covers of a bed.
Trial and appeals.
Byrd, Shepherd, and Miller were charged with conspiracy to commit violations and violations of federal narcotics laws. At first, all three filed a motion to suppress the evidence, arguing that it was seized without probable cause. The trial court denied the motion, and they were convicted of all charges. They then appealed to The Court of Appeals for the District of Columbia Circuit, which upheld their conviction:
Decision.
In a 7-2 majority opinion authored by Justice William Brennan, with a concurrence by Justice John M. Harlan, the Court ruled that the arrest and conviction of all three petitioners violated the Fourth Amendment. The Court's reasoning was that the statutory requirements of law enforcement having to notify a suspect of their authority and purpose were not met. Furthermore, Miller's reaction was reasonable, as the officers did not notify him of their purpose and authority. The mere fact that he attempted to shut the door on them did not necessarily mean that he already knew why they were at his house. The officers could not break the door down and arrest Miller because Miller did not receive any notice in the first place, making the arrest unlawful and the evidence the fruits of an illegal search:
Clark's dissent.
Justice Tom C. Clark dissented, which Justice Harold H. Burton joined, expounding that the Court of Appeals had concluded that Miller knew what purpose the agent and the officer were there for, and he was attempting to destroy evidence by slamming the door. He also argued that slamming the door on officers was not a "normal homeowner's reaction" and that the Court ignored the "exigent circumstances" that was presented in the initial encounter. He wrote that the Court of Appeals: