Horton v. California Case Brief Summary | Law Case Explained

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Horton v. California | 496 U.S. 128 (1990)
For the plain-view exception to the Fourth Amendment’s search warrant requirement to apply, a police officer must see evidence of a crime from a lawful vantage point and the incriminating nature of the evidence must be immediately apparent. But does an officer also need to discover the evidence inadvertently for the exception to apply? The Supreme Court addressed this issue in Horton versus California.
Two masked men robbed Erwin Wallaker, brandishing an Uzi machine gun. One of the robbers used an electric stun gun to subdue Wallaker. The robbers took his money and jewelry. Wallaker recognized the voice of one of the robbers as that of Terry Horton, whom Wallaker knew. After the robbers fled, Wallaker called the police and told officers that one of the robbers was Horton. They applied for a warrant to search Horton’s home. Although the warrant application requested authority to enter Horton’s home to search for both the items taken from Wallaker and the weapons used during the robbery, the search warrant issued by a state judge only mentioned the items taken during the robbery.
The officers searched Horton’s home pursuant to the warrant. Although they didn’t find any of the items taken from Wallaker during the robbery, they did see the Uzi machine gun, two stun guns, and clothing that matched what one of the robbers wore in plain view. The officers seized that evidence and arrested Horton. A state prosecutor charged him with armed robbery and related charges.
Horton moved to suppress the evidence seized during the search on the ground that, although the evidence was in plain view, the officers didn’t discover it inadvertently since they had anticipated that such evidence might be in Horton’s house. The trial court denied the motion, and Horton was convicted at a jury trial. On appeal, the California Court of Appeal affirmed his conviction, and the California Supreme Court denied review.
Horton successfully petitioned the United States Supreme Court to review his case.
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