People v. Brunsting, 307 P.3d 1073

Talent reported his stolen van at Brunsting's residence and warned the vehicle owner might be involved with armed, dangerous individuals.
Five deputies and a sergeant responded, arriving at night to a house lit by a single exterior light.
The owner denied knowledge of the van; she confirmed a man named Lance rented the basement and that four people were inside.
Deputies observed a security camera system around the home, raising officer-safety concerns about being ambushed.
Deputy Carroll entered Brunsting's backyard to avoid the camera and potential ambush, hiding in a bush after initial deployment.
The entry led to the detention of four individuals and discovery of guns and evidence related to methamphetamine manufacture.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether probable cause existed to enter the curtilage	Brunsting contends lack of probable cause to enter property.	People argue probable cause supported entry due to stolen van and criminal activity nearby.	Probable cause existed to enter the property.
Whether exigent circumstances/officer safety justified the curtilage entry	Brunsting argues no exigent circumstances to bypass warrant.	People contend officer safety threats justified rapid entry.	Officer safety concerns fall within exigent circumstances; entry was justified.
Scope and manner of the initial entry into the curtilage	Brunsting argues the entry was beyond reasonable measures.	People argue entry was a reasonable minimal intrusion given risk to officers.	Entry into curtilage was reasonable in manner and scope under exigent circumstances.
Whether subsequent conduct after entry tainted the evidence	Brunsting contends post-entry actions were unlawful if initial entry was unlawful.	People focus on validation of initial entry; remaining issues to be resolved on remand.	Court remands to address post-entry conduct and remaining issues.
Standard of review for suppressioin in exigent circumstances	Brunsting asserts strict warrant-requirement protections apply.	People rely on totality-of-circumstances and existing Fourth Amendment standards.	Reasonableness under totality-of-circumstances governs, reviewing de novo the ultimate legal conclusion.

Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency doctrine; home entry presumptively unreasonable absent exigent circumstances)
Florida v. Jardines, 133 S. Ct. 1409 (S. Ct. 2013) (curtilage and trespass doctrine; modern expectations of privacy around home)
Oliver v. United States, 466 U.S. 170 (U.S. 1984) (curtilage protection and open fields doctrine)
Minnesota v. Olson, 495 U.S. 91 (U.S. 1990) (emergency threats to safety; warrantless intrusion allowed)
Warden v. Hayden, 387 U.S. 294 (U.S. 1967) (hot pursuit and imminent danger justify warrantless searches)
Winpigler, 8 P.3d 439 (Colo. 1999) (extinguishes exigent claim where warrant could have been obtained without compromising safety)
Aarness, 150 P.3d 1271 (Colo. 2006) (armed suspect; protective sweep and entry analyzed under exigent circumstances)
Smith, 13 P.3d 300 (Colo. 2000) (officer safety concerns justify temporary detentions and gunpoint entries in some contexts)
Storey v. Taylor, 696 F.3d 987 (10th Cir. 2012) (two-part test for officer safety exigency)
King, 133 S. Ct. 1958 (U.S. 2013) (totality-of-the-circumstances approach to exigent circumstances)
Martin, 618 F.3d 1295 (10th Cir. 2010) (exigent circumstances arising from danger to officers)
Aarness (Colorado), 150 P.3d 1274 (Colo. 2006) (armed suspect; reasonableness under exigent circumstances)