Lum v. Koles

Summary

The court reversed summary judgment for the police officers and the Borough on the Lums’ trespass and invasion-of-privacy claims. It held that conflicting evidence about what the officers heard, observed, and intended when they entered the home created genuine issues of material fact concerning bad faith and whether the warrantless entry was justified by the emergency-aid exception. The court also held that undisclosed information known only to the dispatcher could not be imputed to the officers to establish the probable-cause-like basis required for warrantless home entry.