Supreme Court of Delaware

Carl Hall, Defendant Below-Appellant v. State of Delaware, Plaintiff Below-Appellee

March 3, 20112011 Del. LEXIS 137

Summary

The Supreme Court of Delaware affirmed Hall’s convictions after concluding that the warrantless protective sweep of his residence was valid under the emergency exception. The officers reasonably sought to determine whether other injured or dangerous persons were present, and the search was not primarily motivated by an intent to arrest or seize evidence. The court held that the Superior Court properly applied the governing three-part emergency-exception test and that the record supported its findings.