State v. Hallam, 2012 Ohio 5793

Hallam was convicted of illegal cultivation of marijuana after a no contest plea and sentenced to one year of community control.
Appeal challenges the trial court’s denial of Hallam’s motion to suppress evidence obtained during a warrantless entry.
Deputy Hensley responded to a welfare check at 3787 Miller Road regarding missing children and a possible custodial dispute.
Hensley entered the residence after the front door was found ajar, observing the home as disarray and indicating possible entry for emergency aid.
Downstairs, Hensley discovered marijuana plants with heat lamps and a fan in a makeshift room, which was seized in plain view.
The trial court ruled exigent circumstances justified the warrantless entry; Hallam argues no such circumstances existed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were exigent circumstances justifying warrantless entry?	Hallam argues no emergency or danger existed.	Hallam contends there was no distress or forced entry.	Exigent circumstances existed; entry deemed reasonable.
Is the marijuana evidence admissible under the plain-view/emer gency doctrine?	Evidence admissible because it was in plain view during lawful entry.	Without exigent entry, discovery would violate Fourth Amendment.	Evidence admissible; discovery was in plain view during lawful entry.

Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusionary rule applies to state actions)
Katz v. United States, 389 U.S. 347 (U.S. 1967) (requirement of probable cause and reasonableness in searches)
State v. Hyde, 26 Ohio App.2d 32 (1971) (emergency/exigent circumstances for entry into a residence)
State v. Roach, 8 Ohio App.3d 42 (1982) (emergency entry limitations and reasonableness)
Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (temporal and proportional limits on exigent entries)