AI Generated Opinion Summaries

Decision Information

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • On December 5, 2013, law enforcement was dispatched to the Defendant's apartment due to a noise complaint. Upon arrival, the officer heard sounds suggesting distress inside the apartment but received no response to knocks and announcements. The officer entered the apartment without a warrant, finding two adults, two small children, and an infant, with the adults appearing intoxicated. The Defendant was charged with child abuse following the officer's entry and observations (paras 3-5).

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Defendant-Appellant: Argued that the evidence obtained during the warrantless entry of his home should be suppressed and claimed that the offense to which he pled was nonexistent, rendering the plea agreement invalid (para 1).
  • Plaintiff-Appellee: Contended that the officer had reasonable grounds to enter the apartment under the emergency assistance doctrine (para 6).

Legal Issues

  • Whether the district court erred in denying the Defendant's motion to suppress evidence obtained during the officer's warrantless entry into his residence.
  • Whether the offense to which the Defendant pled was nonexistent, rendering the plea agreement invalid.

Disposition

  • The order denying the Defendant's motion to suppress evidence was reversed, allowing the Defendant to withdraw his plea. The court did not address the issue regarding the validity of the plea agreement due to the reversal of the suppression motion order (para 15).

Reasons

  • The Court of Appeals, with Judge M. Monica Zamora authoring the opinion, and Judges Jonathan B. Sutin and Timothy L. Garcia concurring, found that the warrantless entry into the Defendant's apartment did not satisfy the requirements of the emergency assistance doctrine as outlined in State v. Ryon. The court determined that the facts known to the officer prior to entry did not constitute credible and specific information indicating a compelling or genuine emergency necessitating swift action to prevent imminent danger to life or serious injury. Consequently, the evidence obtained as a result of the illegal entry should have been suppressed. The court acknowledged the challenging decisions law enforcement officers must make but emphasized the strict requirements for entering and searching a home without consent (paras 7-14).
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