Lange v. California

Arthur Lange (plaintiff) drove past a California highway patrol officer while blasting music and repeatedly honking his horn. The officer signaled Lange to stop, but Lange instead drove an additional 100 feet to park in his own garage. The garage was attached to, and part of, Lange’s home. The officer followed Lange into his garage, questioned him, and conducted a field sobriety test, which Lange failed. A later blood test found Lange’s blood alcohol content was over three times the legal limit. California (defendant) charged Lange with driving under the influence of alcohol, a misdemeanor. Lange moved to suppress all evidence the officer collected after entering Lange’s garage. California countered, arguing that hot pursuit of a fleeing suspected misdemeanant always justified a warrantless home entry. The California Court of Appeals ruled in the state’s favor, holding that (1) Lange’s failure to immediately pull over when the patrol officer signaled him to stop created probable cause to arrest him for the misdemeanor of failing to comply with a police signal; and (2) pursuit of Lange, a fleeing misdemeanant, justified the officer’s warrantless entry into Lange’s garage. The California Supreme Court denied review. Because lower courts across the United States were split on whether pursuit of a fleeing misdemeanant counted as a categorical exception to the Fourth Amendment’s warrant requirement, the United States Supreme Court granted certiorari.