State v. Aguilar, 267 P.3d 1193

Officer patrol uncovers a methamphetamine arrest at a motel; woman identifies room 211 as the source.
Motel manager later says room 214 is the location of drag sales and that defendant occupies it, known as Wedo.
Two men with warrants are arrested in the motel; one is found with a meth pipe; they mention going to room 214 to party with Wedo.
Officers conduct a knock-and-talk to room 214 to develop probable cause/reasonablesuspicion for further investigation.
Defendant opens the door after a short countdown; officers notice marijuana on a table and smell marijuana.
A warrant search of the room yields meth, drag paraphernalia, and other drugs; defendant is charged and moves to suppress all evidence from the entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless motel-room entry was lawful	State contends probable cause plus exigentcircumstances justified entry.	Aguilar argues he was forced to open the door; no exigency or consent justifies entry.	Evidence suppressed; entry unlawful; reverse judgment

State v. Decker, 119 Ariz. 195, 580 P.2d 333 (1978) (Ariz. 1978) (requires both probable cause and exigent circumstances for hotel-room entry without consent or warrant)
State v. White, 160 Ariz. 24, 770 P.2d 328 (1989) (Ariz. 1989) (enumerates exigent circumstances doctrine)
State v. Gissendaner, 177 Ariz. 81, 865 P.2d 125 (App. 1993) (Ariz. App. 1993) (exigent circumstances framework applied in Arizona)
Ker v. California, 374 U.S. 23, 83 S. Ct. 1563, 10 L. Ed. 2d 103 (1963) (probable cause standard for searches)
Stauffer, 112 Ariz. 26, 536 P.2d 1044 (1975) (Ariz. 1975) (probabilities in evaluating probable cause)
Brinegar v. United States, 338 U.S. 160, 69 S. Ct. 1302, 93 L. Ed. 1879 (U.S. 1949) (probability-based reasonableness standard for probable cause)
Kentucky v. King, 563 U.S. _, 131 S. Ct. 1849 (2011) (U.S. 2011) (exigent circumstances not created by police conduct; knock-and-talk specifics analyzed)