Wilson v. Layne, 119 S.St. 1692 (1999)
In Wilson, The United States Supreme Court faced the issue of whether a media "ride along" during the execution of an arrest warrant violates the Fourth Amendment to the United States Constitution.
Facts:
Federal and state officials created a national fugitive apprehension program. One of the dangerous fugitives identified to be arrested was Dominic Wilson. The address on file for Wilson was that of his parents. Officers obtained an arrest warrant to apprehend Wilson at the home. Representatives of the media accompanied the officers as they executed the arrest warrant. Wilson's parents were in the home, but Dominic Wilson was not present. While in the home, newspaper photographers took pictures of Wilson's father, clad only in briefs. The reporters were not otherwise involved in the execution of the warrant.
Wilson's parents sued the law enforcement officers, claiming that the presence of the media during the warrant execution process violated the parents' Fourth Amendment right to be free from an unreasonable search and seizure. The District Court denied the officers' motion for summary judgment on the basis of qualified immunity (see discussion below). On appeal, the Court of Appeals reversed that judgment and upheld the defense of qualified immunity. The United States Supreme Court agreed to hear the Wilson's appeal.
ISSUE:
Wilson v. Layne presents two issues: first, do law enforcement officers violate the Fourth Amendment by inviting members of the media to be present during warrant executions; and secondly, if so, can the officers in this case be successfully sued for allowing the media to attend the warrant's execution.
DISCUSSION:
The Fourth Amendment guarantees, in part, "the right of the people to be secure in their houses." "Physical entry into the home is the chief evil against which the wording of the Fourth Amendment is directed". United States v. United States District Court, 407 U.S. 297 (1972). Court rulings have long been sensitive to the sanctity of the home and, absent consent, a warrant, or an emergency, law enforcement officers may not enter a home to make an arrest or search for evidence. See Payton v. New York, 445 U.S. 573 (1980) (arrest warrant needed to enter Payton's home); Steagald v. U.S. , 451 U.S. 204 (1981) (entry into a third party's home to make an arrest requires a search and arrest warrant). In this case, law enforcement officers were entitled to enter the Wilson home, since they had a warrant. Chief Justice Rehnquist, however, ruled that the officers were not entitled to bring the press with them: "certainly the presence of reporters inside the home was not related to the objectives of the authorized intrusion". In short, ruled the Court, there was no legitimate reason to have the press present during the execution of the warrant. The importance of the press in informing the general public about the administration of criminal justice is not, in and of itself, sufficient reason to override the Fourth Amendment rights of homeowners.
The Supreme Court stressed, however, that there may be times when the presence of third parties would be authorized. If, for example, law enforcement officers are looking for forged art work, they may require an expert to help them locate the forgeries. It is, however, "a violation of the Fourth Amendment for police to bring media or other third parties into a home during the execution of a warrant when the presence of the third parties in the home was not in aid of the execution of the warrant".
The Supreme Court next had to decide whether the officers faced liability for the Fourth Amendment violation. Law enforcement officers generally are granted "qualified immunity" from suit: in other words, the law shields you from liability for civil damages insofar as your conduct does not violate a clearly established constitutional right. What all this legalese boils down to is this: if your conduct was objectively reasonable, that is, if a reasonable officer in your position could believe he was not violating a person's rights, then you are immune from suit. Thus, in order to prevail in a lawsuit against a law enforcement officer, the plaintiff must allege two things: first, that the officers violated a federal right; and secondly, that the right was clearly established at the time of the alleged violation.
It is obvious in this case that the first prong of this test was met, since the Supreme Court decided that media ride-along during the execution of a warrant are unconstitutional. The critical question is thus whether the officers in the Layne case should have reasonably known that bringing media observers into the home was unlawful. The Supreme Court decided that the officers were immune from suit since there was no way for them to know at the time that the constitution was being violated. The Court noted that there were no judicial opinions holding that media ride-along were illegal prior to the Layne case.
WHAT THIS CASE MEANS TO LAW ENFORCEMENT OFFICERS
Layne makes clear that law enforcement officers may not allow members of the press or other non-essential third parties to be present during the execution of an arrest or search warrant. Officers have been put on notice by the United States Supreme Court that failure to adhere to this rule may result in civil liability, as well as suppression of evidence found inside the home. Thus, departments are advised not to allow any non-essential personnel to be present during warrant executions.