State of Arizona v. Bradley Harold Wilson
237 Ariz. 296
Ariz.2015Background
- Neighbors complained about Wilson's erratic behavior; mercury potentially in residence; firefighters and police entered to assess mercury presence; marijuana plants found in laundry room after entry; warrant obtained and marijuana seized; Wilson charged with production of marijuana and possession of drug paraphernalia; suppression denied and court of appeals reversed on community caretaking; Arizona Supreme Court reversed and held community caretaking does not extend to homes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exigent circumstances or emergency aid justify warrantless home entry | Wilson | State | Exigent/emergency exceptions do not justify home entry (assumptions for analysis) |
| Whether the community caretaking exception applies to homes | Wilson | State | Community caretaking does not extend to homes; only to automobiles |
Key Cases Cited
- Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (exigent circumstances required for warrantless searches)
- Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency aid doctrine supports warrantless entry to aid occupants)
- Cady v. Dombrowski, 413 U.S. 433 (U.S. 1973) (limits of community caretaking in the automobile context)
- Opperman v. United States, 428 U.S. 365 (U.S. 1976) (inventory/search rationale for automobiles; privacy expectations for homes remain higher)
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (home entry generally requires a warrant absent exigent circumstances)