Vale v. Louisiana

399 U.S. 30 (1976)

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Nature of the Case

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Facts

Officers possessing warrants for Vale's (D) arrest had information that D was residing at a specified address. They drove to the address in an unmarked car and set up surveillance of the house. The officers observed a green Chevrolet drive up and sound the horn. The car backed into a parking space and sounded the horn again. D came out of the house, walked up to the passenger side of the car, and briefly conversed with the driver. After looking up and down the street, D returned to this house. The officers knew D because they had arrested him two times in the previous month. Within a few minutes, D came outside again, cautiously looked up and down the street, and proceeded to the passenger side of the car, leaning through the window. The officers were convinced a narcotics sale had taken place. The officers drove toward D, who ran toward the house. Three officers got out of the car and told D to stop as he reached the stairs of the house. Officers informed D that they were going to search the house on the basis of the transaction that just occurred. After informing D of his constitutional rights, the officers found narcotics in a bedroom. The Louisiana Supreme Court held that the search of the house did not violate the 4th Amendment because it occurred in the immediate vicinity of D's arrest. D appealed.