State v. Minear, 191 Ohio App. 3d 774

Appellee Minear was charged with OVI, speeding, and hit-and-run after rear-ending another vehicle and leaving the scene.
Police learned of the crash from a driver who described Minear and obtained Minear’s license plate, confirming address at Woodland Apartments, 833 Frost Road, Apt. 502.
Officers located Minear’s parked vehicle on the apartment lot, noted damage, and grew concerned about his welfare since he did not respond after knocking.
After multiple attempts to contact the occupant and having a manager respond, the officers knocked on windows and saw a motionless, face-down body inside.
They entered the apartment without a warrant to check on the occupant’s welfare and observed signs of intoxication; Minear later tested .222 BAC.
Minear moved to suppress the evidence, which the trial court granted; the State appeals, seeking suppression reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exigent circumstances supported warrantless entry?	Minear argues no exigent emergency existed.	Minear contends the entry lacked emergency justification.	Exigency existed; entry justified.
Was the trial court’s factual support for exigency properly reviewed?	State asserts findings support exigency.	Minear contends some facts were misconstrued; no exigency.	Appellate review affirmed exigency based on undisputed facts; some trial findings rejected.
Does the emergency-aid exception allow warrantless entry regardless of motive?	State emphasizes objective emergency aiding injured occupant.	Minear argues subjective intent irrelevant; no emergency seen.	Objective emergency justified entry; officer motive irrelevant.

Michigan v. Fisher, 130 S. Ct. 546 (U.S. 2009) (emergency-aid exception requires objective basis that someone needs aid)
Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (reasonableness depends on objective justification, not officer mindset)
Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (emergency need to protect life justifies warrantless entry)