United States v. Michael Wolfe, 452 F. App'x 180

May 3, 2010, Wolfe is shot; police respond and escort Wolfe from Brown’s home to hospital.
Sergeant Evans arrives after initial responders, observes blood, and follows a blood trail to Wolfe’s upstairs bedroom.
Officers find a plastic bag on Wolfe’s bed and, suspecting narcotics, obtain a search warrant and seize drugs and a firearm.
Wolfe is arrested and later makes incriminating statements; district court suppresses evidence from the bedroom and statements.
District Court finds exigent circumstances justified entry initially but not the later second-floor search; government appeals.
Court must determine whether Evans’s warrantless second-floor search violated the Fourth Amendment and, if so, affirm suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Evans’s second-floor search lawful under exigent circumstances?	Wolfe	Evans had an objectively reasonable basis for danger; there may be additional victims or threats.	No; no objectively reasonable basis found; suppression affirmed.
Was Evans’s initial entry into the home lawful without a warrant?	Wolfe	Exigent circumstances justified initial entry to protect life or limb.	No; government failed to show exigent circumstances to justify initial entry; suppression affirmed.

Payton v. New York, 445 U.S. 573 (U.S. 1980) (home-entry warrant requirement; presumptively unreasonable without warrant)
Coolidge v. New Hampshire, 403 U.S. 443 (U.S. 1971) (exigency exceptions to warrant requirement)
Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency aid and imminent danger)
Michigan v. Fisher, 130 S. Ct. 546 (S. Ct. 2010) (emergency aid requires objectively reasonable basis for medical assistance or danger)
Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (warrantless search must be strictly circumscribed by exigencies; extended investigation not allowed when no ongoing emergency)
Hayden v. United States, 387 U.S. 294 (U.S. 1967) (exigent circumstances in response to reported crime)