Lange v. California
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The Facts
Arthur Lange drove home while playing loud music and honking his horn. A California highway patrol officer followed him into his garage before the door closed. Lange was charged with a DUI misdemeanor and challenged the warrantless entry. California courts applied a categorical rule that any hot pursuit of a fleeing suspect justifies warrantless home entry. The Supreme Court rejected the categorical rule.
The Application
California's categorical hot-pursuit rule permitted the officer to enter Lange's garage based solely on the fact of pursuit, without assessing whether the pursuit of a DUI misdemeanor created genuine exigent circumstances. The Fourth Amendment instead requires a case-by-case inquiry examining whether the specific crime, the threat of flight or harm, and circumstances of the pursuit justify warrantless entry into the home. Applied to Lange's facts (a low-level offense with no imminent danger or threatened evidence destruction), the categorical approach could not stand, shifting enforcement against misdemeanor suspects from blanket authority to individualized Fourth Amendment scrutiny.
The Conclusion
Decided June 23, 2021. The 9-0 ruling (Kagan writing) rejected a categorical misdemeanor hot-pursuit exception. Police must demonstrate actual exigency not just flight to justify warrantless home entry in misdemeanor cases. The decision is a significant Fourth Amendment limit on police authority to enter homes during low-level offense pursuits.
No circuit court data for this case.
Case Analysis
Overview
Lange v. California (2021) held 9-0 that the pursuit of a fleeing misdemeanor suspect does not categorically justify a warrantless entry into a home. The Court rejected a categorical hot-pursuit exception for misdemeanors, holding that whether exigent circumstances justify a warrantless home entry must be assessed case by case, with the gravity of the crime and imminence of harm informing the analysis.
Facts
Arthur Lange drove home while playing loud music and honking his horn. A California highway patrol officer followed him into his garage before the door closed. Lange was charged with a DUI misdemeanor and challenged the warrantless entry. California courts applied a categorical rule that any hot pursuit of a fleeing suspect justifies warrantless home entry. The Supreme Court rejected the categorical rule.
Issue
Whether the Fourth Amendment's hot-pursuit exception categorically allows police to enter a home without a warrant when in pursuit of a fleeing misdemeanor suspect.
Rule
Fourth Amendment generally requires a warrant before police enter a home. The exigent circumstances exception permits warrantless entry in cases of imminent danger, threatened destruction of evidence, or hot pursuit of a fleeing felon. United States v. Santana (1976) recognized hot pursuit of a fleeing felon as exigent. The question is whether the exception applies categorically to all felony and misdemeanor pursuits or requires case-by-case analysis.
Analysis
California's categorical hot-pursuit rule permitted the officer to enter Lange's garage based solely on the fact of pursuit, without assessing whether the pursuit of a DUI misdemeanor created genuine exigent circumstances. The Fourth Amendment instead requires a case-by-case inquiry examining whether the specific crime, the threat of flight or harm, and circumstances of the pursuit justify warrantless entry into the home. Applied to Lange's facts. A low-level offense with no imminent danger or threatened evidence destruction. The categorical approach could not stand, shifting enforcement against misdemeanor suspects from blanket authority to individualized Fourth Amendment scrutiny.
Conclusion
**Decided June 23, 2021. The 9-0 ruling (Kagan writing) rejected a categorical misdemeanor hot-pursuit exception.** Police must demonstrate actual exigency, not just flight, to justify warrantless home entry in misdemeanor cases. The decision is a significant Fourth Amendment limit on police authority to enter homes during low-level offense pursuits.
Notes
OT2020. Added via SCOTUS bulk import 2026-05-14
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