Jonathan D. Carpenter v. State of Indiana, 18 N.E.3d 998

Carpenter appeals after police entered his home without a warrant to corral a bloody dog after a backyard dog fight report.
Officers observed dogs through an open sliding door and noted a fourth dog hiding under a deck; animal control personnel entered to secure the animals.
A search warrant for Carpenter’s home was later obtained based on information from the officers’ observations during the unlawful entry.
Carpenter was charged with multiple felonies and a misdemeanor; he moved to suppress the evidence challenged as obtained in violation of Article 1, Section 11 of the Indiana Constitution.
The trial court denied suppression; the Court of Appeals affirmed, but this Court granted transfer to review the legality of the entry and suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless entry was reasonable under Article 1, Section 11	State argues entry to aid occupants was objectively reasonable	Carpenter contends entry was unnecessary and unlawful without danger to persons inside	Entry was unreasonable under Section 11
Whether the warrant was tainted by illegality of the entry	State relies on observations during lawful warrant execution	Carpenter asserts tainted evidence should be excluded	Suppression affirmed; evidence cannot be used

Holder v. State, 847 N.E.2d 930 (Ind. 2006) (empty-house risk to child justified entry when imminent danger is suspected)
VanWinkle v. State, 764 N.E.2d 258 (Ind. Ct. App. 2002) (entry permitted to prevent imminent danger from volatile chemicals)
Moran v. State, 644 N.E.2d 536 (Ind. 1994) (homes receive the highest protection; warrantless home searches are presumptively unreasonable)
Gerschoffer v. State, 763 N.E.2d 960 (Ind. 2002) (Indiana Section 11 focuses on totality of the circumstances, not Katz approach)
Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (three-factor test for reasonableness of searches under Section 11)