State of Alaska, Petitioner v. Robert Duane Gibson, Iii, Respondent

Summary

The Alaska Supreme Court held that the Alaska Constitution provides greater protection against warrantless residential entries during emergencies than the federal Constitution and adopted a three-part emergency-aid test requiring reasonable grounds to believe an emergency exists, a non-investigatory primary purpose, and a reasonable connection between the emergency and the place searched. Applying that test, the court held that officers reasonably believed an unknown injured person might remain inside the trailer after responding to a violent and ambiguous domestic-disturbance call, so the initial warrantless entry was justified. The court reversed the court of appeals and remanded for consideration of Gibson's challenges to the subsequent searches. Justice Christen, dissenting, would have held that the first prong was not satisfied because the entry rested on speculation rather than objective facts.