District of Columbia v. Little, 339 U.S. 1 (1950)

District of Columbia v. Little


No. 302


Argued January 11-12, 1950
Decided February 20, 1950
339 U.S. 1

CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

Syllabus

Receiving information that respondent’s home was in an unsanitary condition, a health officer went there, without a search warrant, for the purpose of inspecting it. Respondent was away and the door was locked, but she returned while the officer was standing outside the door. She protested his right to enter, claiming that it would violate her constitutional rights, and she refused to unlock the door; but she neither used nor threatened force of any kind. She was convicted of violating a District of Columbia regulation making it a misdemeanor to interfere with or prevent the inspection of any building reported to be in an unsanitary condition.

Held:

1. Respondent’s mere refusal to unlock the door on substantial constitutional grounds was not the kind of interference prohibited by the regulation. Pp. 4-7.

2. The foregoing conclusion makes it unnecessary to decide whether the Fourth Amendment forbade the health officer to enter respondent’s home without a search warrant. Pp. 3-4.

85 U.S.App.D.C. 242, 178 F.2d 13, affirmed on other grounds.

Respondent was convicted of violating a District of Columbia regulation making it a misdemeanor to interfere with or prevent the inspection of a building reported to be in an unsanitary condition. The Municipal Court of Appeals of the District of Columbia reversed on constitutional grounds. 62 A.2d 874. The Court of Appeals affirmed. 85 U.S.App.D.C. 242, 178 F.2d 13. This Court granted certiorari. 338 U.S. 866. Affirmed on other grounds, p. 7.