State v. Scofield

The emergency aid exception applies when officers have an “objectively reasonable belief, based on articulable facts, that a warrantless entry is necessary to either render immediate aid to persons, or to assist persons who have suffered, or who are imminently threatened with suffering, serious physical injury or harm.” State v. Baker, 350 Or 641, 649, 260 P3d 476 (2011).

Defendant appealed a judgment of conviction. The defendant assigned error to the trial court's denial of his motion to suppress evidence arguing the emergency aid exception did not apply. The emergency aid exception applies when officers have an “objectively reasonable belief, based on articulable facts, that a warrantless entry is necessary to either render immediate aid to persons, or to assist persons who have suffered, or who are imminently threatened with suffering, serious physical injury or harm.” State v. Baker, 350 Or 641, 649, 260 P3d 476 (2011). The Court reasoned that there was a reasonable belief here, because when they entered the defendant’s home they had yet to find the victim and the refrigerator was lying on the floor with blood nearby. Given the information the police had at this time, they could have reasonably believed that there was a victim inside the refrigerator.