Owens v. State, 2012 WY 14

Owens pled guilty conditionally to felony possession of methamphetamine and reserved the right to appeal suppression.
A Gillette police officer responded to a 911 medical emergency and was led to Owens's motel room.
The officer found Owens convulsing and unable to communicate; he searched Owens's backpack.
The officer later retrieved a cardboard box from Owens's friend's motel room; no warrant reference was made.
After Owens was hospitalized, the officer secured the room and later obtained a search warrant for the room.
Owens challenged the warrantless search as unlawful; the district court denied suppression and Owens appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should the backpack search be suppressed as unlawful?	Owens argues no connection to emergency justifies the search.	State argues community caretaker justified warrantless search.	Yes, search was reasonable under community caretaker doctrine.

Pena v. State, 98 P.3d 857 (Wy. 2004) (Fourth Amendment analysis in emergencies; reasonableness of searches)
Morris v. State, 908 P.2d 931 (Wy. 1995) (emergency aid and limited warrantless searches)
Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (emergency searches and exigent circumstances)
Wilson v. State, 874 P.2d 215 (Wy. 1994) (community caretaker function in emergencies)
Cady v. Dombrowski, 413 U.S. 433 (U.S. 1973) (police action to protect public safety outside of crime detection)