State v. Schultz, 248 P.3d 484

On April 4, 2004, Sequim police received a report of yelling from an apartment; officers overheard voices as they approached.
Schultz answered the door; she appeared agitated; officers entered after Robertson emerged from a nearby bedroom, without Schultz being asked for permission.
Inside, officers separated Schultz and Robertson; Schultz claimed no one else was there and later disclosed the male voice earlier heard.
Officers observed a handgun and a marijuana pipe; Hill secured the weapon and sought consent to search for more narcotics, which Schultz gave.
Schultz revoked her consent after further questioning; Hill sought a search warrant by telephone, and the apartment was searched revealing methamphetamine.
Trial court denied suppression; Court of Appeals affirmed; Supreme Court granted review to address the emergency aid exception and acquiescence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Emergency aid exception applicability	Schultz	State	Emergency aid not satisfied; entry unlawful
Acquiescence vs. consent	Schultz	State	Acquiescence does not equal consent under article I, §7
Domestic violence context in evaluating reasonableness	State	Schultz	Domestic context may inform reasonableness but did not justify entry here

State v. Thompson, 151 Wash.2d 793 (2004) (emergency aid from community caretaking function)
State v. Kinzy, 141 Wash.2d 373 (2000) (three-part test for emergency aid exception)
State v. Ferrier, 136 Wash.2d 103 (1998) (knock and talk; need to inform right to refuse)
State v. Khounvichai, 149 Wash.2d 557 (2003) (limits on applying Ferrier; consent context)
State v. Williams, 142 Wash.2d 17 (2000) (consent context; arrest warrant considerations)
State v. Afana, 169 Wash.2d 169 (2010) (good faith alone not enough; statutory protections relevance)
State v. Lynd, 54 Wash.App. 18 (1989) (reasonableness of officer's entry evaluated at scene)