State v. Adams, 2017 UT App 205

Deputy Johnson conducted a welfare check at Timothy Adams’s home after Adams’s elderly mother reported not hearing from him for several days and expressed grave concern given his ongoing health problems.
On arrival, Deputy Johnson found a light on, an open window with an extension cord running into a crawl space, moist ground under the crawl space, tools and a ladder left in place, and no vehicles present; neighbors also had not seen Adams for two–three days.
After knocking and announcing himself with no response, and at the mother’s urging to “use whatever means necessary,” Deputy Johnson entered through the open window and observed indoor marijuana cultivation but did not find Adams.
Deputy Johnson then obtained a warrant; when he returned with the warrant, Adams was leaving with marijuana plants; police executed the warrant and later obtained a second warrant for a rifle and phone.
Adams was charged with producing and intending to distribute a controlled substance. He moved to suppress evidence as fruit of an unlawful warrantless entry; the district court denied the motion, finding the entry justified by the emergency-aid doctrine.
Adams pleaded guilty to the two felonies while reserving his right to appeal the suppression ruling; the Court of Appeals affirmed the denial of suppression.

Issue	State's Argument	Adams's Argument	Held
Whether Deputy Johnson’s warrantless entry was permissible under the emergency-aid (exigent-need) exception	Entry was reasonable: mother’s report of health problems, near-daily contact pattern, neighbors hadn’t seen Adams, signs someone had been working under the house, open window and powered crawl-space light supported a reasonable belief Adams might be inside and need assistance	Mother’s worry about not hearing for several days did not amount to an emergency; and after surveying the property, Deputy Johnson had no objective basis to believe an emergency existed inside the home (no visible person, no vehicle, no one seen inside)	Court affirmed: under an objective-reasonableness test (Brigham City/Michigan v. Fisher), facts known to Deputy Johnson supported a reasonable belief of an emergency inside, so warrantless entry was lawful.
Whether evidence from subsequent warrants is fruit of unlawful search	If initial entry lawful, subsequent warrants and seizures are valid	If initial entry unlawful, all later evidence should be suppressed as fruit of the poisonous tree	Because initial entry was lawful under the emergency-aid exception, later warrants and seizures were not fruit of an illegal search and evidence was admissible.

Brigham City v. Stuart, 547 U.S. 398 (2006) (warrantless entry justified when officers have an objectively reasonable basis to believe occupants are seriously injured or threatened)
Michigan v. Fisher, 558 U.S. 45 (2009) (officers need not have ironclad proof of life-threatening injury; objectively reasonable belief suffices)
Mincey v. Arizona, 437 U.S. 385 (1978) (exigency exception to warrant requirement where circumstances make warrantless search objectively reasonable)
Payton v. New York, 445 U.S. 573 (1980) (physical entry into a home is presumptively unreasonable absent a warrant)
Kentucky v. King, 563 U.S. 452 (2011) (warrant requirement subject to reasonable exceptions; reasonableness is the touchstone)