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Name: Martin v. City of Oceanside
Case #: 02-56177
Court: US Court of Appeals
District 9 Cir
Opinion Date: 03/11/2004

Where police officers have a reasonable belief that an occupant of a house requires assistance, entry into that house does not violate the Fourth Amendment even where officers fail to announce their purpose for entering. In this case a man called police to ask them to check on the safety of his daughter Traci because he had not heard from her in several days and was concerned about her welfare. Police arrived at the home where Traci lived with the plaintiff, and knocked and rang the doorbell. The occupants were home and aware that a uniformed police officer was at the door, but did not answer the door because they assumed that the plaintiff’s ex-wife had called police and falsely accused him of a crime. The officers noted the presence of Traci’s car in the driveway, and had a telephone call placed to the residence; again, the occupants failed to answer. An officer then entered an unlocked garage, which led to an unlocked entrance to the house. After a neighbor confirmed that the residents seemed to be home, other officers arrived and entered the house with flashlights and drawn weapons, but left after Traci emerged and identified herself. After the plaintiff filed suit in federal court, the district court granted summary judgment, and the Ninth Circuit affirmed. The appellate court held that the officers were entitled to qualified immunity under the “emergency aid” exception to the warrant requirement, because they had a reasonable belief that an emergency was underway, and because there was no evidence that the officers were motivated by an intent to arrest and seize evidence. Further, the entry was reasonable despite the officers’ failure to announce their purpose prior to entry.