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Maryland v. Buie, 494 U.S. 325 (1990)

Facts

Maryland police, holding an arrest warrant for Jerry Lee Buie on suspicion of armed robbery, entered his home. After Buie emerged from the basement and was arrested, an officer conducted a "protective sweep" of the basement for safety reasons and discovered a red running suit linking Buie to the robbery.

Issue

Is a "protective sweep" of a premises permissible under the Fourth Amendment without a search warrant after the arrest of an individual if officers reasonably believe the area may contain threats?

Holding

The Supreme Court ruled that officers may perform a limited and quick "protective sweep" if they reasonably believe the area could harbor individuals posing a danger.

Rationale

The Court justified the sweep as necessary for officer safety during an arrest, asserting that the search's limited scope is a reasonable balance between officer safety and an individual's Fourth Amendment rights.

Summary

The Supreme Court's decision in Maryland v. Buie permits limited protective sweeps during arrests to ensure officer safety, provided there's a reasonable belief of potential danger.