State v. Samuolis

Summary

The court affirmed the denial of the defendant's motion to suppress evidence obtained after police entered his home without a warrant during a well-being check. Applying the emergency exception, the court held that the officers had an objectively reasonable basis to believe that the defendant's elderly father might be injured and require immediate aid, based on his prolonged absence, the unmoved family vehicle, the lack of response, and the extraordinary concentration of flies at a window. The court rejected the claim that the emergency exception had been eliminated by later precedent and did not reach the state's alternative attenuation, inevitable-discovery, or independent-source theories.