State v. Hawkins, 2017 Ohio 715

Hawkins was indicted for cultivation and possession of marijuana after police found marijuana and grow operations in his home following a warrantless entry.
Detective McKenzie responded to a non-emergency neighbor call reporting Hawkins’s front door was open; he did not know the caller’s identity or other call details.
On arrival the front door was wide open, no vehicles were present, and McKenzie saw a young dog inside that was skittish and had not apparently been outside for days.
McKenzie announced himself, received no response, drew his weapon (concerned about burglary), and conducted a sweep of the home to locate any persons; during the sweep he observed marijuana and drug paraphernalia in plain view and later found grow rooms in the basement.
The trial court denied Hawkins’s motion to suppress, applying the emergency-aid (exigent circumstances) exception to justify the warrantless entry; Hawkins entered a no-contest plea and appealed the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless entry/search was justified by the emergency-aid exception	Entry was reasonable because officer reasonably believed someone inside might need immediate aid given an open front door and the dog’s behavior	Entry violated Fourth Amendment; no exigency — no signs of forced entry, no reports of injury, and limited info about the neighbor’s call	Court affirmed: emergency-aid exception applies; officer’s observations (open door, skittish dog, feces, no response) gave specific, articulable facts supporting entry

Burnside v. Ohio, 100 Ohio St.3d 152 (2003) (appellate standard for mixed questions of fact and law in suppression rulings)
Payton v. New York, 445 U.S. 573 (1980) (physical entry of home implicates Fourth Amendment protections)
Brigham City v. Stuart, 547 U.S. 398 (2006) (emergency-aid exigency justifies warrantless entry to prevent serious injury)
Michigan v. Fisher, 558 U.S. 45 (2009) (officers need not have ironclad proof of life-threatening emergency to invoke emergency-aid exception)
Coolidge v. New Hampshire, 403 U.S. 443 (1971) (warrantless searches are per se unreasonable except in narrowly defined exceptions)
Mincey v. Arizona, 437 U.S. 385 (1978) (preserving life or avoiding serious injury can justify warrantless searches)
Terry v. Ohio, 392 U.S. 1 (1968) (Fourth Amendment reasonableness framework)
Roberts v. Ohio, 110 Ohio St.3d 71 (2006) (state bears burden to justify warrantless searches)