State v. Ryder, 23 A.3d 694

Police investigated a missing teenage boy based on a Vermont father's frantic calls; one son reportedly at Ryder's Greenwich residence.
Officer Kelly arrived at Ryder's gated property and observed a couch protruding from the garage and a convertible with the top down, with no answer at the intercom.
Kelly crossed the gate onto the curtilage and, after approaching the house, entered through unlocked French doors to search for the teen.
A reptile was discovered in a bathtub during the interior search; Ryder was later charged with possession of a reptile and risk of injury to a child.
The trial court denied suppression; the Appellate Court affirmed, applying the emergency doctrine to justify the warrantless entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the warrantless curtilage entry justified by the emergency doctrine?	Ryder argues emergency doctrine did not justify entry.	Ryder maintains no emergency existed to permit warrantless intrusion.	No; emergency exception not satisfied.
Did the search commence at the curtilage crossing rather than upon entering the home?	Ryder contends search began at curtilage crossing, affecting reasonableness.	Ryder contends the search began inside, not at the curtilage.	Search began at curtilage crossing; warrantless entry not justified.

State v. Fausel, 295 Conn. 785 (Conn. 2010) (emergency doctrine; objective, totality-of-circumstances test)
State v. Guertin, 190 Conn. 440 (Conn. 1983) (home entry; fourth amendment limitations)
State v. Aviles, 277 Conn. 281 (Conn. 2006) (emergency exception requires objective reasonableness)
State v. Geisler, 222 Conn. 672 (Conn. 1992) (plain-view and emergency search limitations)
State v. Blades, 225 Conn. 609 (Conn. 1993) (missing-person-related emergency entry; heightened factual basis)
Dow Chemical Co. v. United States, 476 U.S. 227 (U.S. 1986) (curtilage concept foundational to Fourth Amendment)