Hall v. State
14 A.3d 512
Del.2011Background
- Police responded to a 911 hang-up; entry conducted after door was opened and occupants were agitated.
- Hall sustained a facial wound; Congo was agitated, and officers observed tense, potentially violent circumstances.
- A gun was found on the kitchen countertop during a protective sweep initiated by officers.
- The police conducted a limited sweep of the residence to ensure no one else was present and to safeguard people and property.
- Hall was indicted on multiple counts; the State dismissed some counts before trial and Hall was convicted on the remaining charges.
- The Superior Court denied Hall’s suppression motion, applying the Guererri emergency exception test; the appellate court affirmed the ruling and judgments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the emergency exception justified the warrantless search | State argues Guererri three-part test satisfied; search was for emergency aid. | Hall argues the search violated Guererri by being primarily investigative/unspecific to emergency. | Yes; Guererri test satisfied; suppression affirmed. |
Key Cases Cited
- Guererri v. State, 922 A.2d 403 (Del. 2007) (establishes Guererri three-part emergency exception framework and scope)
- Blake v. State, 954 A.2d 315 (Del. 2008) (applies Guererri framework in Delaware context)
- Mincey v. Arizona, 437 U.S. 385 (198?) (emergency aid exception scope and reasonableness support)
- Tierney v. Davidson, 133 F.3d 189 (2d Cir. 1998) (persuasive comparison on emergency searches in domestic disputes)
- State v. Frankel, 847 A.2d 561 (N.J. 2004) (recognizes emergency-response rationale in 9-1-1 contexts)