State v. Hyde, 899 N.W.2d 671

Deputies responded after Hyde’s brother called non-emergency dispatch reporting Hyde had made "suicidal comments" to their mother the previous night (around 12:45 a.m.).
Dispatcher logged the call as a routine, low-priority welfare check; deputies arrived the next morning (shortly before 10:20 a.m.).
Deputies spoke with the landlord, who said Hyde likely was home and appeared fine the prior night; an SUV in the driveway suggested Hyde was present.
Deputies knocked repeatedly for about nine minutes with no answer, then entered through an unlocked door and searched for Hyde without a warrant.
Officers found a marijuana plant in one bedroom and located Hyde asleep in another; Hyde admitted to using a sleeping pill and consented to officers taking plants; a subsequent warrant search yielded additional marijuana.
Hyde moved to suppress evidence obtained from the warrantless entry; district court denied suppression; Hyde entered a conditional guilty plea reserving the right to appeal suppression denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the emergency (exigent) exception justified the warrantless entry into Hyde's home	State: deputies reasonably believed an immediate emergency existed to protect Hyde from harm based on a family report of suicidal comments and indicators Hyde was home	Hyde: report was vague, remote in time (~9 hours), lacked corroboration or evidence of imminent danger, so no immediate emergency justified entry	Reversed: emergency exception did not apply; entry was not supported by reasonable grounds of an immediate need for assistance

State v. Stewart, 851 N.W.2d 153 (N.D. 2014) (warrantless home searches presumptively unreasonable; emergency-exception framework)
State v. Matthews, 665 N.W.2d 28 (N.D. 2003) (three-factor test and objective-reasonableness standard for emergency entry)
State v. Huber, 793 N.W.2d 781 (N.D. 2011) (emergency exception applied where officer smelled dangerous fumes)
State v. Nagel, 308 N.W.2d 539 (N.D. 1981) (definition of exigent circumstances)
Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency-aid exception—officer belief must be objectively reasonable)
Michigan v. Fisher, 558 U.S. 45 (U.S. 2009) (emergency-aid subset of exigent circumstances; focus on perceived need to render aid)
Michigan v. Tyler, 436 U.S. 499 (U.S. 1978) (distinction between exigent circumstances and warrant requirement when immediate action is necessary)
People v. Davis, 497 N.W.2d 910 (Mich. 1993) (rejecting emergency exception where reports were ambiguous and officers observed no signs of immediate injury)
Sutterfield v. City of Milwaukee, 751 F.3d 542 (7th Cir. 2014) (treated delayed, corroborated medical/physician report as supporting emergency entry; discussed suicide-threat contexts)