Warden v. Hayden

Police received a call that an armed man had just stolen money from a taxi company. Taxi drivers gave a description of the armed man, including the clothing he was wearing, and informed the police that the man had just entered a private residence. Police officers arrived at the home in less than five minutes. A woman let the officers inside to search the house. An officer found Bennie Hayden (defendant) upstairs, pretending to sleep. Around the same time, another officer found two firearms in a toilet tank in the house, and officers found ammunition matching the firearms in Hayden’s bedroom. Meanwhile, downstairs, other officers continued to search for any other men in the house. One officer opened a washing machine, found clothing that matched the description of the robber’s clothing, and seized the clothing. Once the officers confirmed there were no other men in the house, they arrested Hayden. The firearms, ammunition, and clothing were admitted as evidence during Hayden’s trial. Hayden was convicted, and his state-court appeals were unsuccessful. Hayen filed a habeas corpus petition in federal court, arguing that the warrantless search of his home and the warrantless seizure of the clothing violated his Fourth Amendment rights. The district court denied the petition. The United States Court of Appeals for the Fourth Circuit affirmed that the search was lawful but ruled that the clothing evidence was inadmissible under the mere-evidence rule. The United States Supreme Court granted certiorari.