James Javonte Crite v. Commonwealth of Kentucky

Summary

The Kentucky Supreme Court affirmed the denial of Crite’s motion to suppress and upheld his conviction and sentence. It held that the lease’s emergency-entry provision authorized the landlord and electrician to enter because extensive electrical damage threatened the safety and habitability of the apartment complex, and that the landlord could request limited police assistance to ensure their safety. The officers’ brief sweep for persons was within the scope of that consent, and their seizure of the firearm was valid under the plain-view doctrine.