State v. Kendrick, 314 Conn. 212

Background

Police in New Jersey had an arrest warrant for Malik Singer in a homicide; the murder weapon was not recovered and Singer was believed armed and at large.
A cellular "ping" tied a phone believed to be used by Singer to 239 Knickerbocker Avenue (a three‑story multifamily building); Stamford officers investigated and the landlord indicated an African‑American man associated with the third‑floor unit.
Around 11 p.m.–midnight officers (some in plainclothes with badges displayed) went to the third‑floor apartment, were invited inside by tenant Blanca Valvo, and were told (or shown) that two African‑American men were in the rear bedroom with her daughter.
New Jersey officers immediately entered the darkened bedroom; defendant Kendrick was in bed with a woman, another man was on a mattress on the floor, and Kendrick lunged toward an object beside the bed.
Officers secured the men and searched the area where Kendrick lunged, finding a partially opened backpack containing a loaded revolver; Kendrick later admitted knowledge of the gun.
Defendant moved to suppress the bedroom entry as warrantless and unlawful; trial court denied the motion, jury convicted Kendrick of criminal possession of a firearm, Appellate Court reversed, and the state sought certification to appeal to the Supreme Court.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Kendrick)	Held
Whether warrantless entry into bedroom was justified by exigent circumstances	Officers reasonably believed entry necessary to protect safety of officers/occupants given ping, landlord tip, and Valvo’s report there were two African‑American men inside	Entry violated Fourth Amendment because police lacked sufficient, specific facts that Singer was present or that immediate entry was necessary; should have obtained a warrant	The Supreme Court held exigent circumstances justified entry; reversal of Appellate Court and affirmation of trial court denial of suppression
Whether police needed direct evidence Singer was in the bedroom to justify entry	No; totality of circumstances and reasonable officer standard suffice; no single factor is determinative	Yes; police required stronger proof/specific articulable facts tying Singer to the bedroom	Court rejected requirement of "direct evidence" of Singer’s presence and applied totality‑of‑circumstances test
Whether the cellular ping and landlord tip were sufficiently reliable and timely to narrow the search	Ping, landlord information, and Valvo’s confirmation together reasonably narrowed the target area to the unit and supported a safety‑based entry	Ping was vague/timing uncertain and landlord’s description was too general to support entry	Court found the combined information sufficient for a reasonable officer to believe immediate entry was necessary
Whether protective sweep or emergency doctrines controlled analysis	Exigent‑circumstances doctrine applies because police had an arrest warrant and probable cause related to Singer; protective sweep doctrine also implicated; emergency doctrine not implicated	Argues protective/emergency doctrines do not rescue the entry absent stronger facts	Court clarified doctrines, applied exigent‑circumstances standard, and concluded entry was reasonable under totality of circumstances

Key Cases Cited

State v. Guertin, 190 Conn. 440 (Conn. 1983) (adopts totality‑of‑circumstances test for exigent circumstances)
State v. Aviles, 277 Conn. 281 (Conn. 2006) (discusses exigent‑circumstances analysis and distinguishes emergency doctrine)
Maryland v. Buie, 494 U.S. 325 (U.S. 1990) (authorizes limited protective sweeps to ensure officer safety)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (articulable facts required for reasonable belief in limited searches/seizures)
Kentucky v. King, 563 U.S. 452 (U.S. 2011) (recognizes split‑second judgments by officers in rapidly evolving, dangerous situations)
State v. Mann, 271 Conn. 300 (Conn. 2004) (applies protective sweep reasoning where officers lacked probable cause but reasonably believed person might be armed)
State v. Ryder, 301 Conn. 810 (Conn. 2011) (discusses heightened scrutiny for nighttime home intrusions)
State v. Blades, 225 Conn. 609 (Conn. 1993) (outlines emergency doctrine for caretaking entries)
State v. Gant, 231 Conn. 43 (Conn. 1994) (describes exigent circumstances categories and limitations)
State v. DeMarco, 311 Conn. 510 (Conn. 2014) (addresses reliance on undisputed officer testimony when reviewing suppression rulings)