CA4: Officers had reasonable cause to believe defendant at home for entry under Payton

Officers had reasonable cause under Payton to believe that defendant was hiding in his own house. The SWAT team showed up for a misdemeanor arrest because of defendant’s 100 prior arrests and numerous convictions for violent crime. After a lot of looking, he was found hiding in a return air duct under the house. A gun was found similarly hidden. United States v. Hall, 495 Fed. Appx. 319 (4th Cir. 2012):

On these facts, we hold that the officers had reason to believe that Hall was inside the house at the time of entry. Officers knew the house was Hall’s residence and possessed several pieces of information suggesting he was at home. First, officers recognized Hall’s vehicle in the driveway. Second, officers knew someone was in the house and not responding to their knocks. Further, Hall’s wife and two of her children ultimately emerged, as did Phillips, who reported, as credited by the district court, the fact of Hall’s presence inside. Therefore, officers had “reason to believe” Hall was inside the residence at the time of entry under Payton.