Facts of the Case

Using marked money, police officers made an undercover heroin buy from a third party who, upon taking money from the officers, entered "Mom Santana's" house and emerged with heroin. Officers then arrested the third party and returned to Santana's house where they identified themselves as police officers, entered the house after Santana fled into it from the porch, and, after ordering her to empty her pockets, discovered some of the marked money. The search was done without a warrant.

Question

Did the search violate the Fourth Amendment?

Conclusion

The Court upheld the search. Relying on the the Court's decision in United States v. Watson (1976), Justice Rehnquist argued that by standing on her porch when the officers arrived, Santana was "not in an area where she had any expectation of privacy." Since the police had probable cause to arrest and search her at that point, their behavior was consistent with the Court's Watson precedent.