State v. Owen, 10 A.3d 1100

Defendant Ricky Owen was convicted after a jury trial of carrying a pistol without a permit and criminal possession of a pistol or revolver.
Owen moved to suppress all evidence and statements allegedly obtained illegally, without a warrant or probable cause.
At suppression, police testified they heard gunshots around 2:52 a.m. near Pettway's Store and observed four men fleeing as shots were fired.
Three men were stopped outside 1050 Stratford Avenue and found unarmed; the fourth man fled inside the residence.
Police surrounded 1050 Stratford Avenue and, after Wanda Smith consented to a search under conditions, entered the home where Owen was found on a couch in his underwear.
A .357 revolver with spent and live rounds was found in a bedroom seconds after entry; Owen was arrested.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exigent circumstances justified the warrantless entry	State argued exigent circumstances existed to enter to prevent destruction of evidence and capture a suspect.	Owen contends the entry was unlawful and not supported by exigent circumstances.	Exigent circumstances justified the entry; motion to suppress denied.

State v. Jenkins, 298 Conn. 209 (Conn. 2010) (standard of review for suppression and constitutional questions)
State v. Spencer, 268 Conn. 575 (Conn. 2004) (exigent circumstances exception to the warrant requirement)
State v. Gant, 231 Conn. 43 (Conn. 1994) (objective test for exigent circumstances)
State v. Aviles, 277 Conn. 281 (Conn. 2006) (emergency/exigent considerations in home entries)
State v. Klauss, 19 Conn. App. 296 (Conn. App. 1989) (distinction between exigent circumstances and emergency doctrine)
State v. Mann, 271 Conn. 300 (Conn. 2004) (heightened protection of the home and lawful search rationale)