Background
Police went to the home where Colin Garret Heys was living after another resident reported that Heys was there and allowed officers to enter. Officers had verified an arrest warrant for Heys, although the warrant listed a different address. They found Heys upstairs, told him he was under arrest, and ordered him to put his hands on his head.
Heys refused to comply, pulled his arms away as officers tried to handcuff him, and kicked an officer. A jury convicted him of two counts of resisting and obstructing a police officer. He argued that the arrest was unlawful because of the warrant’s address discrepancy and the officers’ entry into the home, and challenged the jury instructions.
The Court’s Holding
The Michigan Court of Appeals affirmed. An arrest warrant must adequately identify the person to be seized and be supported by probable cause; unlike a search warrant, it need not particularly describe the place where an arrest may occur. Thus, the different address on the arrest warrant did not invalidate it.
The evidence also allowed the jury to find the arrest lawful. Officers had a valid warrant, reason to believe Heys lived in and was inside the home, and consent from another resident to enter. Heys’s later demand that officers leave did not negate their authority to arrest him in his own home under the warrant. The trial court properly declined a consent instruction and adequately instructed the jury on the legality element.
Key Takeaways
- An arrest warrant is directed to a person, not a particular location.
- A valid arrest warrant permits officers to enter a suspect’s home when they have reason to believe the suspect is inside.
- A defendant’s later objection to officers’ presence does not undo a lawful warrant-based entry and arrest.
Why It Matters
The decision distinguishes the particularity requirements for search warrants from those governing arrest warrants. It also confirms that, in a resisting-and-obstructing prosecution, evidence of a valid arrest warrant and lawful authority to enter can establish the lawfulness of the officers’ actions.