Court Says Officer's Warrantless Entry into Home Was Justified

Case: People v. Kevonian

Court: Michigan Court of Appeals ( Unpublished Opinion )

Issues:

Search & seizure; Whether Fourth Amendment rights were violated; Whether the warrantless entry into defendant’s home fell under the community-caretaking or emergency-aid exceptions to the search warrant requirement; People v. Galloway; U.S. Const. amend. IV; Const. 1963, art. 1, § 11; People v. Jordan; People v. Levine; People v. Davis; People v. Lemons; Brigham City v. Stuart; People v. Hyde; Good-faith; People v. Hill

Summary:

The court held that the trial court properly concluded that Sergeant P’s warrantless entry into defendant’s home was justified under the emergency-aid exception to the warrant requirement. Thus, it held that the trial court properly denied his motion to suppress the evidence obtained as a result of the entry. After observing a large amount of blood in and around defendant’s home, P entered the home without a warrant. “Based upon evidence obtained during the execution of the search warrant, defendant was charged with committing various drug-related offenses.” He moved in limine to suppress the evidence claiming it was the product of an unconstitutional warrantless search. The trial court denied his motion, concluding that the warrantless entry was proper under the emergency-aid exception. On appeal, he argued that his Fourth Amendment rights were violated because the warrantless entry into his home did not fall under the community-caretaking or emergency-aid exceptions to the search warrant requirement and thus, the trial court erred when it denied his motion to suppress the evidence acquired pursuant to the search warrant. Because the record indicated that P entered defendant’s home upon a good-faith belief that emergency aid may have been necessary, the court held that, even had the emergency-aid exception not applied, the trial court still would have properly denied defendant’s motion. Affirmed.