State v. Armbruster, 2013 Ohio 3119

November 21, 2011, Norton police received a tip that Room 315 at the Berlin Motel was actively cooking meth.
Officer Canterbury approached, smelled a strong chemical odor associated with meth, and kicked in the door after occupants refused entry.
Inside, a working meth lab was observed; occupants Armbruster and another were arrested; tenants were evacuated for safety.
Indictment charged Armbruster with illegal manufacturing, illegal assembly/possession of chemicals, and aggravated trafficking, each with forfeiture specifications; Armbruster later pled no contest to illegal manufacturing and the linked forfeiture; other charges dismissed; four-year sentence.
Suppression motion filed; trial court denied; Armbruster appealed raising a single assignment of error: denial of suppression.
The appeal affirms the trial court’s denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether warrantless entry was justified by emergency/exigent circumstances	State contends there was a reasonable belief of a meth lab creating an emergency.	Armbruster argues absence of ongoing exigency and lack of probable cause.	Exigent circumstances to justify entry were present; suppression denied.

State v. Timofeev, 9th Dist. Summit No. 24222, 2009-Ohio-3007 (Ohio App. 9th Dist. (2009)) (emergency-aid/exigent analysis for meth labs)
State v. White, 175 Ohio App.3d 302, 2008-Ohio-657 (9th Dist. 2008) (necessity of urgent action when meth lab suspected)
State v. Sandor, 9th Dist. Summit No. 23353, 2007-Ohio-1482 (Ohio App. 9th Dist. (2007)) (exigent circumstances framework for meth lab cases)
State v. Pape, 11th Dist. Ashtabula No. 2004-A-0044, 2005-Ohio-4657 (Ohio App. 11th Dist. (2005)) (multifactor exigency analysis)
State v. Burnside, 100 Ohio St.3d 152, 2003-Ohio-5372 (Ohio Sup. Ct. (2003)) (framework for reviewing suppression determinations)
State v. Hobbs, 133 Ohio St.3d 43, 2012-Ohio-3886 (Ohio Sup. Ct. (2012)) (exigent circumstances and suppression standards)