State v. Hendrix, 2014 Ohio 3577

Neighbors reported the Suffolk Downs house garage door was left open for days; police arrived and observed no evident signs of break‑in or other unusual activity.
Officers entered the home through the closed but unlocked garage door after confirming the open garage and attempting to contact neighbors.
Inside, officers discovered a marijuana grow operation in an upstairs room.
Hendrix and Scott were charged with possession, illegal cultivation, trafficking, criminal tools, and Hendrix with weapons under disability.
The trial court granted suppression; on remand, the court again suppressed; the State appealed, arguing the emergency‑aid exception justified the entry.
The appellate court affirmed, concluding the emergency‑aid exception did not justify a warrantless entry under the circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the emergency‑aid exception justified the warrantless home entry.	Hendrix argued emergency aid excused the entry.	Hendrix contends no emergency existed justifying intrusion.	No; emergency aid did not justify the entry.

State v. Burnside, 100 Ohio St.3d 152 (Ohio 2003) (review of suppression; mixed questions of law and fact)
State v. Metcalf, 2007-Ohio-4001 (Ohio 2007) (application of Fourth Amendment to facts; de novo review of law)
State v. Nields, 93 Ohio St.3d 6 (Ohio 2001) (warrantless home entry; emergency aid burden on state)
Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency aid exception; need to assist or protect life)
Mincey v. Arizona, 437 U.S. 385 (Supreme Court 1978) (exigencies exception to warrantless searches; objective reasonableness)
Welsh v. Wisconsin, 466 U.S. 740 (U.S. 1984) (home entry presumptively unreasonable; exceptions apply)
State v. Applegate, 68 Ohio St.3d 348 (Ohio 1994) (limits on warrantless entry; strict circumscription by exigencies)
Nelms v. Wellington Way Apts., LLC, 513 Fed.Appx. 541 (6th Cir.2013) (emergency aid standard; cannot rest on mere possibility)