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Name: People v. Troyer
Case #: S180759
Court: CA Supreme Court
District CalSup
Opinion Date: 02/22/2011
Summary

The emergency-aid exception to the Fourth Amendment justifies an officer’s entry into a residence and, under some circumstances, a locked bedroom if there is an objectively reasonable basis for believing that medical assistance is needed, or a person is in danger. Officers responded to a residence within minutes of a reported shooting and found two people on the front porch, one with gunshot wounds and the other bleeding heavily from a head wound. The report mentioned a victim possibly may have been shot twice, but no such victim was found outside the residence. Neither person on the porch was able (or willing) to give information as to whether there was anyone in the residence. However, there was blood on the front door indicating an injured victim may have entered the residence. The police entered and found no one downstairs. Upstairs, an officer forced entry into a locked bedroom and found marijuana and a scale. A warrant subsequently was obtained and a more thorough search of the room revealed weapons, a large sum of money, and indicia linking appellant to the room. Appellant’s suppression motion was denied at the trial court level. The appellate court reversed, reasoning that the police were justified in the initial entry into the residence but not the bedroom. The Supreme Court disagreed with the appellate court and ruled that the entry into both the residence and the bedroom were reasonable as a search for possible victims. Although searches of a residence are presumptively unreasonable under the Fourth Amendment, law enforcement officers may enter a home without a warrant to provide emergency assistance to an injured occupant or protect an occupant from imminent injury. This exception requires only an objectively reasonable basis for believing a person within the house requires assistance, and does not depend on the officer’s subjective intent or the seriousness of the crime being investigated. Additionally, the locked bedroom door posed obvious risks to the officers as they were searching the upstairs, which also justified the entry.