State v. Mattocks, 2013 Ohio 4965

Officers responded to a 1:00 a.m. domestic-disturbance 911 call: caller Patience Mattocks reported being shoved, locked out, and prevented from calling police by her husband, Pierre Mattocks.
Officers knocked and called Pierre by dispatch; Pierre refused to come to the door initially, then warned police to "be off his property" when he would come down.
At the rear sliding glass door Pierre appeared holding a flashlight and a handgun at his right thigh; he flashed the light at officers, said "Castle Law," and initially did not drop the gun when ordered.
Pierre later removed the magazine and slide from the handgun and placed them on the kitchen table, unlocked the door, then began to walk away; officers ordered him to the ground, he failed to comply, they entered, struggled, and handcuffed him.
Police recovered the handgun with hollow-point rounds and an unloaded shotgun; Pierre was charged with resisting arrest, domestic violence, and having weapons while under disability.
Trial court granted Pierre’s motion to suppress based on lack of exigent circumstances and unlawful entry; the State appealed and the appellate court reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exigent circumstances justified warrantless entry	Officers reasonably feared for officer and victim safety because Pierre confronted them visibly armed and uncooperative	No exigency once Pierre disabled the gun and placed it on the table; no immediate threat justified entry	Reversed: exigent circumstances existed given officer safety risk and conduct (gun, manipulation, threats, "Castle Law")
Whether weapons seized should be suppressed	Firearms were lawfully seized as search-incident-to-arrest and/or in plain view after lawful entry	Seizure was fruit of unlawful entry and arrest, so suppression required	Reversed: arrest was supported and weapons were properly seized incident to arrest and in plain view

Welsh v. Wisconsin, 466 U.S. 740 (establishes presumption against warrantless home entries absent exigent circumstances)
Payton v. New York, 445 U.S. 573 (Fourth Amendment draws a firm line at home entry; warrants required absent exigency)
Mincey v. Arizona, 437 U.S. 385 (exigency includes need to protect life or avoid serious injury)
Chimel v. California, 395 U.S. 752 (limits of search-incident-to-arrest to arrestee and area within immediate control)
Arizona v. Gant, 556 U.S. 332 (search-incident-to-arrest doctrine tied to officer safety and evidence preservation)
United States v. Bates, 84 F.3d 790 (6th Cir.) (weapon presence plus threats or violent tendencies can create exigency)
State v. Williams, 55 Ohio St.2d 82 (sets elements for plain-view seizure)