Caleb Aaron Campbell, 339 P.3d 258

Officers responded to a welfare check request about Sean Homolka at his last-known Laramie apartment; they observed lights on, a TV playing, a barking dog, window coverings, and fresh footprints in the snow. No one answered initial knocks.
Sergeant Austin opened an unlocked front door a few feet, announced himself, and observed a blue glass bong on a counter. He closed the door, contacted the caller, then located and spoke with Caleb Campbell at a restaurant; Campbell agreed to meet officers at the apartment.
At the apartment, Campbell produced and destroyed some paraphernalia but initially did not produce the observed blue bong; he later brought it out and broke it. He acknowledged having a small amount of marijuana and flushed some down the toilet.
Austin asked to re-enter to confirm disposal; Campbell consented to entry and to searches of several bedrooms and a bathroom. Officers then discovered a mushroom grow operation and over three ounces of marijuana in subsequent consensual searches.
Campbell was charged with multiple felonies, moved to suppress evidence arguing the initial warrantless entry and subsequent searches violated the Fourth Amendment, and after the district court denied suppression he entered a conditional guilty plea to felony marijuana possession to preserve appeal.

Issue	Plaintiff's Argument (Campbell)	Defendant's Argument (State)	Held
Whether the initial entry fell within the emergency-assistance exception	Opening the unlocked door and peering inside was an unlawful warrantless entry; no genuine emergency existed	Entry justified under emergency-assistance (and community-caretaking) doctrines given apparent signs of someone potentially needing aid	Court: No emergency; initial entry unlawful because facts did not support objectively reasonable belief of an immediate danger
Whether Campbell voluntarily consented to searches of bedrooms, bathrooms, and kitchen	Consent was not voluntary because it was the product of police coercion and/or exploitation of the prior illegal entry	Consent was voluntary; State proved voluntariness by preponderance of the evidence	Court: District court’s factual finding of voluntariness was not clearly erroneous; consent was not coerced
Whether any voluntariness was tainted by the prior unlawful entry (fruit-of-the-poisonous-tree)	Consent was likely tainted because officers exploited information from the initial unlawful entry to obtain further consent	Even if the initial entry was unlawful, subsequent voluntary consent purged the taint and provided an independent source for evidence	Held: Whether consent was tainted is a factual question unresolved below; remanded for district court to determine if the initial illegality contaminated the later consent

United States v. U.S. Dist. Court for E. Dist. of Mich. , 407 U.S. 297 (U.S. 1972) (emphasizes that physical entry of the home is the chief evil against which the Fourth Amendment is directed)
Cady v. Dombrowski , 413 U.S. 433 (U.S. 1973) (source of community-caretaking doctrine and its distinction from emergency-aid doctrine)
Moulton v. State , 148 P.3d 38 (Wyo. 2006) (Wyoming case applying emergency-assistance exception where facts showed a genuine emergency)
Vargas , 63 A.3d 175 (N.J. 2013) (explains emergency-aid doctrine’s higher standard for entry into homes and nexus requirement)
Melendez-Garcia , 28 F.3d 1046 (10th Cir. 1994) (sets factors for determining whether consent following illegality purges taint: temporal proximity, intervening circumstances, purpose/flagrancy of misconduct)
Fox , 600 F.3d 1253 (10th Cir. 2010) (addresses whether consent was sufficiently attenuated from prior illegality)
O'Boyle v. State , 117 P.3d 401 (Wyo. 2005) (allocates burden to State to prove voluntariness of consent by preponderance)