Susan Stricker v. Twp. Of Cambridge, 710 F.3d 350

911 call reported Andrew Stricker overdosed; EMS requested; parents refused entry without warrant; officers entered and conducted search to locate Andrew; Andrew apprehended and treated; deputies arrested Kevin and Susan, Andrew for drug use; district court granted State Defendants’ summary judgment; on appeal, Strickers challenge all Fourth Amendment issues.
The 911 call, observed medical condition of Andrew, and defendants’ attempts to prevent access contributed to exigent circumstances, supporting entry and search under the emergency aid exception.
Officers conducted a protective sweep and searched for Andrew and to obtain information for EMS treatment; the scope included bedrooms and drawers due to concealment concerns and to gather drug-use information.
Probable cause supported arrests for resisting/obstructing and Andrew for drug use; Michigan law on obstruction reflected lawful entry under exigent circumstances; Assistant Prosecutor Riley provided on-call guidance.
Excessive force claim analysis concluded actions were reasonable given evasion and flight attempts; no actionable constitutional violation found; no conspiracy or municipal liability absent underlying violation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exigent circumstances justified warrantless entry	Strickers: no exigency; insufficient medical emergency	State Defendants: 911 call + observations created objective emergency	Yes, exigency justified entry and search
Whether the search was reasonably limited yet adequate	Strickers: overbroad search after Andrew removed	Search needed to locate Andrew and safeguard EMS	Yes, search reasonable under exigent circumstances
Whether there was probable cause for arrests	Strickers: lack of probable cause for obstruction	Officers had reasonable belief of obstruction and need to aid EMS	Yes, probable cause supported arrests for resisting/obstructing and drug use
Whether police used excessive force	Strickers: force excessive and unjustified	Force reasonable given evasion and risk	No, actions not gratuitous under the circumstances
Whether conspiracy/malicious prosecution/municipal liability survive	Strickers: conspiracy and municipality liable without Fourth Amendment violation	No underlying violation; no municipal liability without violation	Dismissed; no viable §1983 claims without a constitutional violation

Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (exigent circumstances to aid or protect occupants in a home")
Kentucky v. King, 131 S. Ct. 1849 (U.S. 2011) (objective reasonableness of emergency-entry decisions; no focus on subjective motives)
Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (exigent circumstances exception for warrants when emergency exists)
Fisher (Michigan v. Fisher), 558 U.S. 45 (U.S. 2009) (emergency aid doctrine; need for immediate medical evaluation)
Thacker v. City of Columbus, 328 F.3d 244 (6th Cir. 2003) (911 call and need to safeguard EMS; scan for danger; medical emergency)
Johnson v. City of Memphis, 617 F.3d 864 (6th Cir. 2010) (911 call dynamics; open door; emergency aid justified entry)
Brooks v. Rothe, 577 F.3d 701 (6th Cir. 2009) (exigent circumstances where overdose risk and concealment present)
McKenna v. Edgell, 617 F.3d 432 (6th Cir. 2010) (searches for medical clues reasonably linked to treatment)
Spurlock v. Thompson, 330 F.3d 791 (6th Cir. 2003) (prosecutor's role and immunity in police context; investigative actions)
Payton v. New York, 445 U.S. 573 (U.S. 1980) (home entry generally unreasonable without warrant; exceptions apply)