350 P.3d 1044
Idaho Ct. App.2015Background
- Hotel security reported a loud domestic dispute involving Heather Heard and Steven Harris; officers responded shortly thereafter.
- Officer Thompson observed Harris awake and Heard lying motionless in the hotel room; Heard did not respond normally when roused and appeared "extremely groggy."
- Thompson entered the room without a warrant, believing Heard might be injured, intoxicated, or otherwise in medical danger and that her safety could be at risk from Harris.
- Upon standing, a small plastic bag fell from Heard onto the bed; officers discovered methamphetamine and syringe marks on Heard’s arms.
- Heard was charged with possession of a controlled substance and paraphernalia; she moved to suppress the drug evidence as the fruit of an unlawful warrantless entry.
- The district court denied suppression, concluding exigent circumstances justified the entry; Heard entered a conditional guilty plea reserving the suppression issue for appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Officer Thompson's warrantless entry violated the Fourth Amendment | Entry was lawful under the exigent-circumstances/emergency-assistance exception to render aid and ensure safety | Warrantless entry into a hotel room was unconstitutional; evidence should be suppressed | The entry was justified by exigent circumstances; suppression denied |
Key Cases Cited
- Hoffa v. United States, 385 U.S. 293 (recognizing hotel rooms are protected by Fourth Amendment)
- Payton v. New York, 445 U.S. 573 (warrant required to enter a home absent an exception)
- Brigham City v. Stuart, 547 U.S. 398 (exigent-circumstances emergency-assistance exception permits warrantless entry)
- Mincey v. Arizona, 437 U.S. 385 (exigency allows warrantless entry to address danger or render aid)
- State v. Robinson, 144 Idaho 496 (Fourth Amendment threshold protection for homes/hotel rooms discussed in Idaho context)
- State v. Bower, 135 Idaho 554 (unresponsiveness and attendant conditions can create exigent circumstances)
- State v. Barrett, 138 Idaho 290 (incoherence/unresponsiveness justified warrantless entry to ascertain cause and protect occupants)