State v. Wilson, 333 P.3d 774

Officers responded to reports of Bradley Wilson behaving strangely and speaking nonsensically; he told medical personnel he had up to seven pounds of mercury in a duct‑tape–wrapped jar at his home and that he and his family had handled and bathed in it.
Fire department volunteer Steven Hardy (experienced with mercury) inspected the situation by phone and on‑site, concluded mercury was potentially hazardous but that ambient temperature made vaporization unlikely.
Hardy and Officer Shumway (without a warrant) entered Wilson’s locked residence together to locate mercury and assess hazard; during a ~10‑minute sweep they smelled marijuana and observed several marijuana plants in a laundry area shielded by a blanket.
Officers exited, obtained a warrant, then seized marijuana, paraphernalia, and firearms; Wilson moved to suppress the evidence as the product of an unlawful warrantless search.
The superior court denied suppression, finding exigent circumstances and plain‑view; this Court reviews the denial de novo as to legal conclusions and reverses, holding the state failed to meet its burden to justify the warrantless entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exigent‑circumstances justified warrantless entry	Officers reasonably believed large mercury spill posed imminent danger justifying immediate entry	No evidence of an imminent hazard to any person or public; temperature and closed house made vaporization unlikely	Denied: exigency not shown; entry was not justified under exigent‑circumstances exception
Whether emergency‑aid exception (medical) justified entry	Entry was to assist in medical treatment/assessment of Wilson and obtain information relevant to care	Wilson was responsive; no evidence locating mercury was necessary for treatment or that care required entry	Denied: facts did not support emergency‑aid exception or need to search for treatment purposes
Whether community‑caretaking function permits warrantless residential entries	Police acted pursuant to community‑caretaking to protect public health/safety	Community‑caretaking recognized for vehicles but should not be extended to homes absent exigency	Denied: community‑caretaking does not justify warrantless entries into residences absent exigent circumstances
Whether evidence should be suppressed	N/A (state sought to admit evidence)	Evidence was product of unlawful warrantless search and must be suppressed	Granted: suppression denial reversed; remanded for further proceedings

State v. Fisher, 141 Ariz. 227 (discussing emergency‑aid exception and warrant requirement)
State v. Decker, 119 Ariz. 195 (exigent‑circumstances framework)
State v. Aguilar, 228 Ariz. 401 (probable cause standard)
State v. Greene, 162 Ariz. 431 (definition of exigent circumstances)
State v. Sainz, 18 Ariz. App. 358 (police/fire responsibility to act on reports)
Brigham City v. Stuart, 547 U.S. 398 (need to protect life/avoid serious injury can justify warrantless entry)
Cady v. Dombrowski, 413 U.S. 433 (community‑caretaking doctrine; distinction between vehicles and homes)
State v. Jacot, 235 Ariz. 224 (observed residential entry upheld where exigency existed)