State v. Willis., 150 Haw. 235

Background

Police had probable cause that Erik Willis committed a random, unprovoked stabbing of a teenager three days earlier based on security video and an officer who identified Willis and knew his address.
HPD surveilled Willis for about a day and a half, then entered his home without consent or a warrant and arrested him.
Officers observed shoes and a shirt inside the home that matched the suspect’s clothing; about two hours later they recovered those items from a family washing machine without a warrant.
Willis was indicted for second-degree attempted murder and moved to suppress the clothing and statements he made while detained at home; the circuit court granted suppression, finding no exigent circumstances.
The State appealed, arguing the stabbing’s violent, “stranger-danger” nature (plus prior biting, prowling surveillance, and an unrecovered knife) created an exigency that justified a warrantless home entry.
The Hawai‘i Supreme Court affirmed: the violent nature of the offense alone did not create exigent circumstances, the State failed to show specific, objective facts requiring immediate action at the time of entry, and the clothing and statements were properly suppressed as fruits of the illegal entry.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exigent circumstances justified the warrantless home entry to arrest Willis	The random, violent stabbing and risk of repeat attack made immediate entry necessary; police could not wait hours to obtain a warrant	Gravity alone insufficient; officers surveilled Willis for 1.5 days, knew his identity and address, had no evidence he was armed or fleeing, and lacked specific facts requiring immediate action	Gravity of the crime alone cannot establish exigency; State must show objective, specific facts independent of offense severity and present at time of entry; no exigency here
Whether seizure of clothing was valid under the plain view doctrine	Items observed in the home matched suspect clothing and therefore could be seized under plain view	Entry was unlawful, so plain view cannot validate the seizure	Plain view inapplicable because the officers’ presence was unlawful; seizure excluded
Whether statements and derivative evidence must be suppressed as fruits of the illegal entry	Statements and clothing admissible	Statements and clothing are fruits of the unlawful home intrusion and must be excluded	Exclusionary rule bars use of the clothing and statements as products of the illegal entry

Key Cases Cited

Payton v. New York, 445 U.S. 573 (home entry to make an arrest is presumptively unreasonable absent an exception)
Florida v. Jardines, 569 U.S. 1 (heightened privacy interest in the home)
Lange v. California, 141 S. Ct. 2011 (exigency inquiry focuses on whether immediate action is required)
Welsh v. Wisconsin, 466 U.S. 740 (seriousness of offense alone does not create exigent circumstances)
Mincey v. Arizona, 437 U.S. 385 (seriousness of offense does not by itself justify warrantless searches)
Caniglia v. Strom, 141 S. Ct. 1596 (courts reluctant to expand warrant exceptions for home entry)
State v. Line, [citation="121 Hawai'i 74, 214 P.3d 613"] (warrantless dwelling entries only justified by exigent circumstances)
State v. Pulse, [citation="83 Hawai'i 229, 925 P.2d 797"] (State must identify specific, articulable facts showing immediate need)
State v. Jenkins, [citation="93 Hawai'i 87, 997 P.2d 13"] (exigency assessed under totality of circumstances)
State v. Naeole, [citation="148 Hawai'i 243, 470 P.3d 1120"] (examples of exigency: imminent harm, escape, or destruction of evidence)
State v. Dias, 62 Haw. 52, 609 P.2d 637 (warrantless-entry justification must rest on more than officers’ subjective belief)
State v. Dorson, 62 Haw. 377, 615 P.2d 740 (exigency must exist at the time of entry)
State v. Meyer, [citation="78 Hawai'i 308, 893 P.2d 159"] (plain view requires a lawful intrusion)
State v. Weldon, [citation="144 Hawai'i 522, 445 P.3d 103"] (exclusionary rule bars evidence discovered as a result of prior illegal police act)