State v. J. Vegas, 463 P.3d 455

In July 2016, Northwest Montana Drug Task Force investigated a tip that Vegas was selling heroin from La Quinta hotel rooms 109 and 111.
Surveillance and hotel staff indicated known drug users/dealers visited Room 111; a housekeeper identified Vegas as the occupant of Rooms 109 and 111 and said he instructed her not to enter/clean them.
Officers knocked and announced at Room 109; Vegas opened the door slightly with the chain on, then shut and locked the door when he saw a uniformed officer.
Officers forcibly entered (kicked down) Room 109 and also entered Room 111, secured both rooms, then obtained a search warrant and found ~54 grams meth, a scale, and cash.
Vegas moved to suppress evidence as fruit of an illegal warrantless search; the District Court found probable cause and exigent circumstances and denied suppression.
Vegas reserved appeal after an Alford plea; the Montana Supreme Court affirmed, holding exigent circumstances justified the warrantless entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless entry and resulting evidence must be suppressed	State: officers had probable cause and specific, articulable exigent circumstances (risk of evidence destruction) justifying immediate entry	Vegas: concedes probable cause but contends no exigency existed to excuse the warrant requirement	Court: affirmed — exigent circumstances existed based on totality (recognizable officers, known drug visitors, and Vegas slamming/locking door)

State v. Ruggirello, 176 P.3d 252 (Mont. 2008) (standard of review for suppression and exigent-circumstances analysis)
State v. Stone, 92 P.3d 1178 (Mont. 2004) (warrantless entry into a home is per se unreasonable absent an exception)
State v. Wakeford, 953 P.2d 1065 (Mont. 1998) (constitutional protections extend to motel room occupants)
State v. Lanegan, 91 P.3d 578 (Mont. 2004) (evaluate exigency under totality of circumstances)
State v. McCarthy, 852 P.2d 111 (Mont. 1993) (totality-of-circumstances approach in exigency analysis)
State v. Logan, 53 P.3d 1285 (Mont. 2002) (State bears heavy burden to show specific, articulable facts supporting exigent circumstances)