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

Summary

The Alaska Supreme Court held that the Alaska Constitution provides greater protection than the federal Constitution in the emergency-aid context and requires satisfaction of a three-prong test for a warrantless residential entry. Applying that test, the court held that officers reasonably believed an injured person might remain inside Gibson's trailer after responding to a violent and ambiguous domestic-disturbance call, so the initial entry was justified. The court reversed the court of appeals and remanded for consideration of Gibson's remaining challenges to the later searches. Justice Christen, dissenting in part, agreed with the test but would have held that the first prong was not satisfied because the officers lacked objective facts supporting an emergency.