United States v. Taylor, 624 F.3d 626

Officer Ratliff responded to a report of a four-year-old girl wandering on a busy street and unable to locate her parents.
The girl led Ratliff to a row house; an interior door was open and the front door had been entered by the occupant. Ratliff entered the home to locate the child’s guardian after hearing no response to his calls.
Inside, Ratliff found Melvin Taylor in a back room with a bag of .22 caliber bullets and a handgun hidden under a mattress; Taylor provided a false name and could not supply valid identification.
Ratliff conducted a protective sweep, questioned Taylor, and after verifying Taylor’s identity, arrested him for felon in possession of a firearm and for providing false information.
The child was left with Taylor’s girlfriend, whom Ratliff confirmed was the child’s mother, before the defendant’s arrest.
Taylor was charged in the Eastern District of Virginia with felon in possession of a firearm; he moved to suppress the gun and statements as fruit of a warrantless search, which the district court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a warrant was required for entry into the home.	Taylor argues a warrant was needed; probable cause was required.	Ratliff should not have entered without a warrant; the home search is within criminal justice norms needing a warrant.	No warrant required under exigent circumstances; entry was reasonable.
Whether the entry was reasonable under the Fourth Amendment.	Existence of an exigency did not justify entering the home.	Exigent circumstances and absence of responsible supervision justified entry to protect the child.	Entry was objectively reasonable due to the child's abandonment and risk to her safety.
Whether the scope of the warrantless entry was barred by the emergency.	Search should have extended beyond merely locating a parent.	The search was strictly circumscribed to finding a parent and ensuring child safety.	Search limited to locating a guardian; protective sweep was justified to ensure safety.
Whether the officer’s actions were reasonable in light of alternatives proposed by Taylor.	Officer could have left a note or sought further non-emergency steps.	Less intrusive or alternative measures would have delayed reunification and risked harm.	Reasonableness does not require the least intrusive means; actions were appropriate to reunite child quickly.

Brigham City v. Stuart, 547 U.S. 398 (2006) (exigent circumstances justify warrantless entry to prevent harm)
Vernonia Sch. Dist. 47J v. Acton, 515 U.S. 646 (1995) (probable cause not universally required outside criminal investigations)
Mincey v. Arizona, 437 U.S. 385 (1978) (exigent circumstances justify warrantless entries to preserve life or prevent harm)
Gwinn, 219 F.3d 326 (4th Cir. 2000) (exigency supports re-entry to obtain clothing when arresting a defendent without shirt or shoes)
Hunsberger v. Wood, 570 F.3d 546 (4th Cir. 2009) (exigent circumstances justified nighttime entry into home; ongoing vandalism and at-risk child)
United States v. Moss, 963 F.2d 673 (4th Cir. 1992) (limited scope of emergency searches; not a general voyage of discovery)
Cephas, 254 F.3d 488 (4th Cir. 2001) (probable cause analysis not controlling outside criminal investigation context)
Georgia v. Randolph, 547 U.S. 103 (2006) (privacy and social understanding inform reasonableness in searches)
Michigan v. Tyler, 436 U.S. 499 (1978) (exigent circumstances permit entry to preserve life and safety without a warrant)
United States v. Johnson, 410 F.3d 137 (4th Cir. 2005) (probable cause not invariably required outside criminal investigation)