State v. Baker

To establish whether a police officer satisfied the reasonableness requirement of the four-part “emergency aid exception” test to the warrantless search exception of the Oregon Constitution, the court should examine whether the police officer had an objectively reasonable belief, based on articulable facts that a warrantless entry was needed to aid others, prevent harm from occurring to others, or cease harm to others.

Defendant was charged with multiple counts for manufacturing and possessing marijuana. At trial, defendant moved to suppress evidence seized by the Medford city police since the police entered his residence without a warrant while responding to a 9-1-1 domestic disturbance call. Specifically, the defendant contended that the warrantless search of his residence fell outside the scope of the “emergency aid exception,” Article I, section 9 of the Oregon Constitution because the emergency had dissipated when the officers entered the room and ended the emergency. The Supreme Court went on to analyze the reasonableness requirement of the four part test of the emergency exception and concluded that a warrantless search is justified if the “police officers have an objectively reasonable belief, based on articulable facts” that a warrantless entry is needed to aid others, prevent harm from occurring, or cease harm to others. In this case, the Court held that based on the information the police officer received prior to beginning investigation, and then later at the defendant’s residence, supported an objectively reasonable belief that an emergency existed. The Court of Appeals Reversed and the judgment of the trial court Affirmed.