State v. Kendrick

Summary

Justice McDonald, joined by Justice Palmer, dissented from the conclusion that exigent circumstances justified the warrantless entry into the apartment bedroom. The dissent reasoned that the police had only an imprecise cell-phone location, an uncertain time frame, and information that a Black man had associated with the tenant's daughter, which did not objectively connect the suspect to the apartment or establish an immediate safety risk. The dissent further concluded that the information learned after entry—that two Black men were in the bedroom—did not cure the lack of exigency before entry. Justice McDonald also criticized the majority for relying on a different factual basis than the trial court and for permitting suspicion based primarily on race.