People v. Troyer
51 Cal. 4th 599
| Cal. | 2011Background
- Police responded to a shooting at 9253 Gem Crest Way; a female victim Zapata and male Abeyta were present, with other suspects reportedly fleeing.
- Blood on the front door and Abeyta’s head wound created fear of additional victims inside; Abeyta provided inconsistent answers about occupants.
- Abeyta unlocked the door after officer threats to force entry; officers entered to locate victims or suspects.
- An upstairs locked bedroom door was knocked, then kicked open by Officer Seo, revealing marijuana paraphernalia and drugs in plain view.
- Defendant Troyer was not home; record shows he had standing to challenge entry; search led to more contraband and weapons with Troyer linked to the residence.
- Court of Appeal reversed suppression; majority found emergency aid justified initial entry but debated the upstairs bedroom, while the Supreme Court reversed and upheld suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether emergency aid justified warrantless entry | People | Troyer | Yes; entry justified under emergency aid doctrine |
| Whether entry into locked upstairs bedroom was justified | People | Troyer | Yes; scope reasonable |
| Whether protective sweep doctrine applies to upstairs bedroom | People | Troyer | Not necessary to rely on Buie; emergency aid sufficed |
| Whether Abeyta's inconsistent statements negate objective basis | People | Troyer | No; inconsistencies did not defeat reasonable basis |
| Whether the police entry violated Fourth Amendment given later suppression | People | Troyer | Yes; suppression proper for unlawful upstairs entry |
Key Cases Cited
- Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency aid requires objective basis for aid)
- Tamborino v. Superior Court, 41 Cal.3d 919 (Cal. 1986) (walk-through search to locate additional victims allowed)
- Celis v. People, 33 Cal.4th 667 (Cal. 2004) (protective sweep concept; emergency/entries tied to safety)
- Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (principles guiding emergency searches in homicide contexts)
- Maryland v. Buie, 494 U.S. 325 (U.S. 1990) (protective sweep doctrine)