Police obtained arrest warrants for Vale (defendant) and sat outside of his house for purposes of surveillance. The officers witnessed Vale come outside and conduct what they believed to be a drug deal in the driveway. The officers arrested Vale on the front steps of his house. The arresting officer then searched the house and found narcotics. At trial, Vale argued that the search of his house violated his Fourth Amendment rights. The Louisiana Supreme Court held that the search was justifiable under the Fourth Amendment. The United States Supreme Court granted certiorari.