State v. Karna, 887 N.W.2d 549

Deputies responded to a call from Karna’s brother reporting Dean Karna had shot their father at the shared trailer residence.
Deputies found Karna outside blocking the entry; after Karna denied shooting their father, a deputy entered the home, saw a rifle on the couch, and detained Karna.
The deputy reentered, called for occupants, received no response, and searched the home to locate the father.
The deputy found the father asleep, checked him for injuries, and concluded he had not been shot; while speaking with the father the deputy asked about other guns.
The father gave consent to search Karna’s bedroom; in the attached bathroom deputies discovered marijuana and drug paraphernalia, leading to charges against Karna.
Karna moved to suppress the evidence as the entry and search were warrantless; the district court denied the motion under the emergency (exigent-circumstances) exception and Karna appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether warrantless entry/search met the emergency-exception requirement that officers had reasonable grounds to believe an immediate emergency existed	Law enforcement had reasonable, objective grounds (identified 911 caller, familiarity with family, reported shooting) to believe the father needed immediate aid	Karna argued no emergency existed to justify warrantless entry; search was unreasonable	Court held deputies had an objectively reasonable belief an emergency existed, so exigent circumstances justified entry; consent search of bedroom then produced evidence

City of Fargo v. Thompson, 520 N.W.2d 578 (N.D. 1994) (standards for reviewing trial court findings in preliminary criminal proceedings)
State v. Nelson, 691 N.W.2d 218 (N.D. 2005) (three-part test for the emergency exception to the warrant requirement)
City of Fargo v. Ternes, 522 N.W.2d 176 (N.D. 1994) (emergency doctrine allows warrantless entry to render aid when officers reasonably believe someone is in distress)
State v. Nagel, 308 N.W.2d 539 (N.D. 1981) (exigent circumstances include imminent danger to life or property)
State v. Swenningson, 297 N.W.2d 405 (N.D. 1980) (valid consent to search following a lawful encounter supports admissibility of discovered evidence)
State v. Huber, 793 N.W.2d 781 (N.D. 2011) (deference to trial court findings of fact on suppression motions; de novo review of legal question whether facts constitute exigent circumstances)
United States v. Cooper, 168 F.3d 336 (8th Cir. 1999) (applies de novo review to ultimate determination of exigent circumstances)