People v. Hill
299 Mich. App. 402
| Mich. Ct. App. | 2013Background
- Defendant was charged with marijuana manufacture (MCL 333.7401(2)(d)(iii)) after police found plants in a bedroom closet.
- Police entered defendant’s home without a warrant following a welfare check prompted by a neighbor’s concerns.
- District court suppressed the evidence, ruling the entry violated the Fourth Amendment; circuit court affirmed; leave to appeal denied.
- Supreme Court remanded for reconsideration; lead opinion held entry under community-caretaking exception was reasonable.
- Court found, applying Slaughter, that actions were motivated by aiding a citizen and were not designed to investigate crime.
- Even if a violation occurred, good-faith exception justified admission of evidence; exclusionary rule not warranted; charge reinstated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does community-caretaking justify warrantless entry? | People contend caretaking exception applies given neighbor concerns and attempts to render aid. | Hill argues entry was not to render aid and lacked articulable facts of need inside the home. | Yes; caretaking applies under totality of circumstances. |
| Was emergency-aid exception satisfied here? | People assert possible need for immediate aid based on circumstances observed. | Beuschlein-style claim that there was no imminent danger or need of assistance. | No; emergency-aid exception not supported by facts. |
| Does the exclusionary rule apply given police actions were in good faith? | Davis-style deterrence warranted suppression for misconduct. | Police acted in good faith; suppression would deter beneficial welfare actions. | No; good-faith exception applies; suppression not required. |
Key Cases Cited
- People v Slaughter, 489 Mich 302 (2011) (framework for de novo review of constitutional questions)
- Davis v United States, 564 U.S. 244 (2011) (good-faith exception and cost-benefit analysis of exclusionary rule)
- People v Frazier, 478 Mich 231 (2007) (exclusionary rule inappropriate absent governmental misconduct)
- United States v. Leon, 468 U.S. 897 (1984) (good-faith reliance on warrants; deterrence not strong with mere negligence)
- Arizona v Evans, 514 U.S. 1 (1995) (good-faith exception extended to erroneous arrest-ww warrant databases)