State v. Laverne Ware, Jr., 968 N.W.2d 752

A 911 caller (Mickey) reported a large amount of blood in the garage of a Fox Lake residence and that his girlfriend S.D. was missing; he suspected the blood might be S.D.’s though he had not seen a body.
Officers went to the home; the resident Marjorie Jones initially said Ware (her son) was not present. Mickey contradicted that, and later Ware unexpectedly appeared and said, “I am the one you are looking for.”
Sergeant Nicholas looked through a screen/metal door, saw blood pooled under a pickup truck, then entered the garage without a warrant and discovered a deceased person in the passenger seat.
Ware was arrested and charged with first-degree intentional homicide, hiding a corpse, incest, and felony firearm possession; he moved to suppress evidence from the warrantless garage search.
The circuit court denied suppression relying on the community caretaker exception; after briefing, the U.S. Supreme Court decided Caniglia (community caretaker cannot justify residential searches) and the State argued the emergency-aid exception instead.
The Court of Appeals affirmed the denial of suppression, holding the warrantless garage entry was justified under the emergency-aid exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless search of the garage was lawful	Initially invoked community-caretaker; after Caniglia, argued emergency-aid justified entry because officers reasonably believed a person in the garage needed immediate medical aid	Search was unconstitutional: no indication of an ongoing medical emergency and community-caretaker cannot justify residential searches	Search justified under the emergency-aid exception: officers had an objectively reasonable basis to believe immediate aid might be needed and entry was necessary

Caniglia v. Strom, 141 S. Ct. 1596 (community-caretaker exception does not permit warrantless searches of residences)
Brigham City v. Stuart, 547 U.S. 398 (officers may enter without a warrant to render emergency assistance)
Michigan v. Fisher, 558 U.S. 45 (emergency-aid inquiry is objective; officers need reasonable basis to believe someone needs immediate aid)
State v. Boggess, 115 Wis. 2d 443 (Wisconsin two‑part emergency-aid test)
State v. Rome, 239 Wis. 2d 491 (applying totality-of-circumstances two-part emergency-aid test)
State v. Anderson, 389 Wis. 2d 106 (citizen informants are generally reliable)
State v. Matalonis, 366 Wis. 2d 443 (significant blood can support reasonable belief victim needs assistance)
State v. Kraimer, 99 Wis. 2d 306 (reports of death may be inaccurate; entry sometimes justified to determine if aid still could be rendered)