State v. Rogers, 2016 SD 83

Police responded to reports that James Rogers told a third party he had killed his girlfriend, Caitlin Walsh, and that her body might be in a suitcase in his apartment; a neighbor reported seeing blood in the apartment.
Officers went to Rogers’ apartment, heard him crying and saying "I’m sorry," and knocked; Rogers eventually unlocked the door but would not come outside and the crying stopped.
Chief Wainman forced entry after unsuccessful attempts to obtain a key; he pulled Rogers into the hallway, asked what happened, and Rogers said he had “done something very wrong” and that Walsh was “in the closet.”
The chief entered the apartment, smelled decomposition, opened the closet, and saw a leaking suitcase that appeared to contain a heavy object; officers left, obtained a warrant ~5 hours later, then seized the suitcase and found Walsh’s remains.
At the sheriff’s office, before full Miranda warnings were completed, Rogers made statements including “I never meant to hurt her” and then, after a full advisement and waivers, admitted stabbing Walsh with a machete; Rogers was tried, convicted of first-degree murder, and sentenced to life without parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether warrantless entry/search of apartment was lawful	Entry/search justified by exigent circumstances (need to protect life)	Entry/search violated Fourth Amendment; warrant required	Exigent circumstances justified entry; search lawful
Whether officers could rely on community-caretaker or inevitable-discovery doctrines	Alternative grounds support warrantless entry/seizure	Constitutional protections not satisfied by those doctrines	Court resolved on exigency and did not reach alternatives
Whether hallway statements ("did something very wrong," "in the closet") should be suppressed under Miranda	Statements were non-custodial or were admissible as on-scene public-safety questions	Statements obtained while in custody without Miranda and should be suppressed	Statements admissible as on-scene, public-safety questions; alternatively, any Miranda error was harmless
Whether pre-Miranda statements required reversal given later admissions and physical evidence	Pre-Miranda statements tainted the investigation and prejudiced the jury	Other admissions and forensic evidence make any error harmless	Any error was harmless beyond a reasonable doubt given other confessions and forensic links

State v. Fischer, 875 N.W.2d 40 (S.D. 2016) (standard for reviewing suppression rulings and warrant exceptions)
Brigham City v. Stuart, 547 U.S. 398 (2006) (exigent circumstances justify warrantless entry to protect life)
Mincey v. Arizona, 437 U.S. 385 (1978) (limits and rationale for warrantless searches in emergency contexts)
Neder v. United States, 527 U.S. 1 (1999) (harmless-error analysis for constitutional errors)
State v. Berget, 826 N.W.2d 1 (S.D. 2013) (harmless-error standard applied to constitutional errors in state cases)