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33 Idaho opinions name it 2 courts 1978–2026 5 in the last five years
The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Michigan v. Tylergreen2 sentences2022Instead, the totality of circumstances surrounding a warrantless blood draw must be evaluated on a case-by-case basis to assure the two essential requirements of the exigent circumstances exception are met: “there is [1] a compelling need for official action and [2] no time to secure a warrant.” See id. at 149 (quoting Michigan v. Tyler, 436 U.S. 499 , 509–510 (1978)). 2019“The exigent circumstances exception does not apply where there is time to secure a warrant.” State v. Robinson, 144 Idaho 496, 501 , 163 P.3d 1208, 1213 (Ct. App. 2007) (citing Michigan v. Tyler, 436 U.S. 499, 509 (1978); State v. Worthington, 138 Idaho 470, 472 , 65 P.3d 211, 213 (Ct. App. 2002)). 6 officers arrived, observed, and questioned the woman who answered the door, was not objectively reasonable.” The district court continued: The officers’ response after only smelling marijuana was not appropriately tailored to the scope of the alleged exigency. | 11 | 12 |
Kentucky v. Kinggreen2 sentences2014The exigent circumstances exception “applies when ‘the exigencies of the situation’ make the needs of law enforcement so compelling that [a] warrantless search is objectively reasonable under the Fourth Amendment.’” King, 563 U.S. at ___ , 131 S. Ct. at 1856 (alteration in original) (quoting Mincey v. Arizona, 437 U.S. 385, 394 (1978)). 2014The exigent circumstances exception “applies when ‘the exigencies of the situation’ make the needs of law enforcement so compelling that [a] warrantless search is objectively reasonable under the Fourth Amendment.’” King, 563 U.S. at ___ , 131 S. Ct. at 1856 (alteration in original) (quoting Mincey v. Arizona, 437 U.S. 385, 394 (1978)). | 3 | 4 |
Mincey v. Arizonagreen2 sentences2014The exigent circumstances exception “applies when ‘the exigencies of the situation’ make the needs of law enforcement so compelling that [a] warrantless search is objectively reasonable under the Fourth Amendment.’” King, 563 U.S. at ___ , 131 S. Ct. at 1856 (alteration in original) (quoting Mincey v. Arizona, 437 U.S. 385, 394 (1978)). 2014The exigent circumstances exception “applies when ‘the exigencies of the situation’ make the needs of law enforcement so compelling that [a] warrantless search is objectively reasonable under the Fourth Amendment.’” King, 563 U.S. at ___ , 131 S. Ct. at 1856 (alteration in original) (quoting Mincey v. Arizona, 437 U.S. 385, 394 (1978)). | 3 | 4 |
State v. Worthingtongreen2 sentences2019“The exigent circumstances exception does not apply where there is time to secure a warrant.” State v. Robinson, 144 Idaho 496, 501 , 163 P.3d 1208, 1213 (Ct. App. 2007) (citing Michigan v. Tyler, 436 U.S. 499, 509 (1978); State v. Worthington, 138 Idaho 470, 472 , 65 P.3d 211, 213 (Ct. App. 2002)). 6 officers arrived, observed, and questioned the woman who answered the door, was not objectively reasonable.” The district court continued: The officers’ response after only smelling marijuana was not appropriately tailored to the scope of the alleged exigency. 2019“The exigent circumstances exception does not apply where there is time to secure a warrant.” State v. Robinson, 144 Idaho 496, 501 , 163 P.3d 1208, 1213 (Ct. App. 2007) (citing Michigan v. Tyler, 436 U.S. 499, 509 (1978); State v. Worthington, 138 Idaho 470, 472 , 65 P.3d 211, 213 (Ct. App. 2002)). 6 officers arrived, observed, and questioned the woman who answered the door, was not objectively reasonable.” The district court continued: The officers’ response after only smelling marijuana was not appropriately tailored to the scope of the alleged exigency. | 3 | 3 |
State v. Barrettgreen2 sentences2015State v. Barrett, 138 Idaho 290, 293 , 62 P.3d 214, 217 (Ct. App. 2003). 2015State v. Barrett, 138 Idaho 290, 293 , 62 P.3d 214, 217 (Ct. App. 2003). | 3 | 3 |
State v. Robinsongreen2 sentences2019“The exigent circumstances exception does not apply where there is time to secure a warrant.” State v. Robinson, 144 Idaho 496, 501 , 163 P.3d 1208, 1213 (Ct. App. 2007) (citing Michigan v. Tyler, 436 U.S. 499, 509 (1978); State v. Worthington, 138 Idaho 470, 472 , 65 P.3d 211, 213 (Ct. App. 2002)). 6 officers arrived, observed, and questioned the woman who answered the door, was not objectively reasonable.” The district court continued: The officers’ response after only smelling marijuana was not appropriately tailored to the scope of the alleged exigency. 2019“The exigent circumstances exception does not apply where there is time to secure a warrant.” State v. Robinson, 144 Idaho 496, 501 , 163 P.3d 1208, 1213 (Ct. App. 2007) (citing Michigan v. Tyler, 436 U.S. 499, 509 (1978); State v. Worthington, 138 Idaho 470, 472 , 65 P.3d 211, 213 (Ct. App. 2002)). 6 officers arrived, observed, and questioned the woman who answered the door, was not objectively reasonable.” The district court continued: The officers’ response after only smelling marijuana was not appropriately tailored to the scope of the alleged exigency. | 2 | 3 |
State v. Araizagreen2 sentences2013However, we note that, in State v. Araiza, 147 Idaho 371 , 209 P.3d 668 (Ct. App. 2009), we upheld the warrantless entry of a residence under the exigent circumstances doctrine given officers’ reasonable concern for the safety of the occupants. 3 III. 2013However, we note that, in State v. Araiza, 147 Idaho 371 , 209 P.3d 668 (Ct. App. 2009), we upheld the warrantless entry of a residence under the exigent circumstances doctrine given officers’ reasonable concern for the safety of the occupants. 3 III. | 2 | 3 |
State v. Blancasgreen2 sentences2026See Blancas, 170 Idaho at 636 , 515 P.3d at 723 . 2026We reaffirm “that to invoke the exigent circumstances exception to the Fourth Amendment, the State must prove, under the totality of circumstances, that a reasonable officer would have believed he was presented with a ‘now or never’ situation.” Blancas, 170 Idaho at 637 , 515 P.3d at 724 . | 2 | 2 |
Payton v. New Yorkgreen2 sentences2014Payton v. New York, 445 U.S. 573, 589-90 (1980). 2014Payton v. New York, 445 U.S. 573, 589-90 (1980). | 2 | 2 |
State v. Wrengreen2 sentences2008The exigent circumstances exception allows agents of the state to conduct a warrantless search when there is a “compelling need for official action and no time to secure a warrant.” Michigan v. Tyler, 436 U.S. 499, 509 , 98 S.Ct. 1942, 1949 , 56 L.Ed.2d 486, 498 (1978); State v. Wren, 115 Idaho 618, 624 , 768 P.2d 1351, 1357 (Ct.App.1989). 2008The exigent circumstances exception allows agents of the state to conduct a warrantless search when there is a “compelling need for official action and no time to secure a warrant.” Michigan v. Tyler, 436 U.S. 499, 509 , 98 S.Ct. 1942, 1949 , 56 L.Ed.2d 486, 498 (1978); State v. Wren, 115 Idaho 618, 624 , 768 P.2d 1351, 1357 (Ct.App.1989). | 2 | 2 |
State v. Rushogreen2 sentences2003At oral argument, Barrett relied upon an exigent circumstances standard as set forth in State v. Rusho, 110 Idaho 556, 559-60 , 716 P.2d 1328, 1331-32 (Ct.App.1986). 2003At oral argument, Barrett relied upon an exigent circumstances standard as set forth in State v. Rusho, 110 Idaho 556, 559-60 , 716 P.2d 1328, 1331-32 (Ct.App.1986). | 2 | 2 |
State v. Pearson-Andersongreen2 sentences2012As this case is factually akin to those cases discussing exigent circumstances, we look at those cases for guidance. 4 Another case discussing the exigent circumstances exception to the warrant requirement that we find to be instructive is State v. Pearson-Anderson, 136 Idaho 847 , 41 P.3d 275 (Ct. App. 2001). 2012As this case is factually akin to those cases discussing exigent circumstances, we look at those cases for guidance. 4 Another case discussing the exigent circumstances exception to the warrant requirement that we find to be instructive is State v. Pearson-Anderson, 136 Idaho 847 , 41 P.3d 275 (Ct. App. 2001). | 1 | 4 |
Brigham City v. Stuartgreen2 sentences2007The state contends that the magistrate erred because a crime need not be a felony to trigger the exigent circumstances exception to the Fourth Amendment’s warrant requirement and because the officers’ actions did not exceed the scope of the evidence preservation exigency. “[W]arrants are generally required to search a person’s home or his person unless ‘the exigencies of the situation’ make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment.” Brigham City, 547 U.S. at-, 126 S.Ct. at 1947 , 164 L.Ed.2d at 657 (quoting Minc 2007The state contends that the magistrate erred because a crime need not be a felony to trigger the exigent circumstances exception to the Fourth Amendment’s warrant requirement and because the officers’ actions did not exceed the scope of the evidence preservation exigency. “[W]arrants are generally required to search a person’s home or his person unless ‘the exigencies of the situation’ make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment.” Brigham City, 547 U.S. at-, 126 S.Ct. at 1947 , 164 L.Ed.2d at 657 (quoting Minc | 1 | 2 |
State v. Wiedenheftgreen2 sentences2009Id. at 17 , 27 P.3d at 876 . 2006See State v. George, 127 Idaho 693, 699 , 905 P.2d 626, 632 (1995) (because the traffic stop did not violate defendant’s right to be free from unreasonable searches and seizures, the defendant obstructed the authorized duty of the officer by refusing to provide her driver’s license); Wiedenhefi, 136 Idaho at 15-16, 27 P.3d at 874-75 (whether defendant was entitled to obstruct the officer’s warrantless entry into her home depended on whether the exigent circumstances exception to the warrant requirement applied). | 1 | 2 |
State v. Sailasgreen2 sentences2003A. Exigent Circumstances The exigent circumstances exception justifies a warrantless search when the facts known to the police at the time of the entry, along with reasonable inferences drawn thereupon, demonstrate a “compelling need for official action and no time to secure a warrant.” Pearson-Anderson, 136 Idaho at 849 , 41 P.3d at 277 ; Sailas, 129 Idaho at 434 , 925 P.2d at 1133 . 2003A. Exigent Circumstances The exigent circumstances exception justifies a warrantless search when the facts known to the police at the time of the entry, along with reasonable inferences drawn thereupon, demonstrate a “compelling need for official action and no time to secure a warrant.” Pearson-Anderson, 136 Idaho at 849 , 41 P.3d at 277 ; Sailas, 129 Idaho at 434 , 925 P.2d at 1133 . | 1 | 2 |
Ornelas v. United Statesgreen1 sentence2022For that reason, we, as “a reviewing court should take care both to review findings of historical fact only 12 for clear error and . . . give due weight to inferences drawn from those facts by resident judges and local law enforcement officers.” Ornelas v. United States, 517 U.S. 690, 699 (1996); State v. Munoz, 149 Idaho 121, 127 , 233 P.3d 52, 58 (2010). | 1 | 1 |
State v. Munozgreen2 sentences2022For that reason, we, as “a reviewing court should take care both to review findings of historical fact only 12 for clear error and . . . give due weight to inferences drawn from those facts by resident judges and local law enforcement officers.” Ornelas v. United States, 517 U.S. 690, 699 (1996); State v. Munoz, 149 Idaho 121, 127 , 233 P.3d 52, 58 (2010). 2022For that reason, we, as “a reviewing court should take care both to review findings of historical fact only 12 for clear error and . . . give due weight to inferences drawn from those facts by resident judges and local law enforcement officers.” Ornelas v. United States, 517 U.S. 690, 699 (1996); State v. Munoz, 149 Idaho 121, 127 , 233 P.3d 52, 58 (2010). | 1 | 1 |
State v. Micah Abraham Wulffgreen2 sentences2020See State v. Wulff, 157 Idaho 416, 420 , 337 P.3d 575, 579 (2014) (stating that the body’s metabolization of alcohol is one factor to consider in an exigent circumstances analysis). 2020See State v. Wulff, 157 Idaho 416, 420 , 337 P.3d 575, 579 (2014) (stating that the body’s metabolization of alcohol is one factor to consider in an exigent circumstances analysis). | 1 | 1 |
State v. O'KEEFEgreen2 sentences2020State v. O’Keefe, 143 Idaho 278, 283 , 141 P.3d 1147, 1152 (Ct. App. 2006). 2020State v. O’Keefe, 143 Idaho 278, 283 , 141 P.3d 1147, 1152 (Ct. App. 2006). | 1 | 1 |
State v. Scheversgreen2 sentences2013State v. Valdez-Molina, 127 Idaho 102, 106 , 897 P.2d 993, 997 (1995); State v. Schevers, 132 Idaho 786, 789 , 979 P.2d 659, 662 (Ct. App. 1999). 1 The magistrate’s rejection of the exigent circumstances doctrine as a basis for the warrantless entry has not been appealed and we need not address that issue. 2013State v. Valdez-Molina, 127 Idaho 102, 106 , 897 P.2d 993, 997 (1995); State v. Schevers, 132 Idaho 786, 789 , 979 P.2d 659, 662 (Ct. App. 1999). 1 The magistrate’s rejection of the exigent circumstances doctrine as a basis for the warrantless entry has not been appealed and we need not address that issue. | 1 | 1 |
State v. Holmangreen1 sentence2013In King, the Court held that “the exigent circumstances rule applies when the police do not gain entry to premises by means of an actual or threatened violation of the Fourth Amendment.” Id. at _____, 131 S.Ct. at 1862 . 5 707 P.2d 493, 498 (Ct. App. 1985). | 1 | 1 |
State v. Valdez-Molinagreen2 sentences2013State v. Valdez-Molina, 127 Idaho 102, 106 , 897 P.2d 993, 997 (1995); State v. Schevers, 132 Idaho 786, 789 , 979 P.2d 659, 662 (Ct. App. 1999). 1 The magistrate’s rejection of the exigent circumstances doctrine as a basis for the warrantless entry has not been appealed and we need not address that issue. 2013State v. Valdez-Molina, 127 Idaho 102, 106 , 897 P.2d 993, 997 (1995); State v. Schevers, 132 Idaho 786, 789 , 979 P.2d 659, 662 (Ct. App. 1999). 1 The magistrate’s rejection of the exigent circumstances doctrine as a basis for the warrantless entry has not been appealed and we need not address that issue. | 1 | 1 |
State v. Diazred2 sentences2008See Diaz, 144 Idaho 300 , 160 P.3d 739 ; State v. Rodriguez, 128 Idaho 521 , 915 P.2d 1379 (Ct.App.1996). 2008See Diaz, 144 Idaho 300 , 160 P.3d 739 ; State v. Rodriguez, 128 Idaho 521 , 915 P.2d 1379 (Ct.App.1996). | 1 | 1 |
| Illinois v. McArthurgreen | 1 | 1 |
| State v. Holtongreen | 1 | 1 |
| State v. Georgegreen | 1 | 1 |
| United States v. Richard Colby Parr and Vincent Rendarogreen | 1 | 1 |
| Michigan v. Cliffordgreen | 1 | 1 |
| Minnesota v. Olsongreen | 1 | 1 |
| State v. Johnsongreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Missouri v. McNeely
green
2 sentences2022Instead, the totality of circumstances surrounding a warrantless blood draw must be evaluated on a case-by-case basis to assure the two essential requirements of the exigent circumstances exception are met: “there is [1] a compelling need for official action and [2] no time to secure a warrant.” See id. at 149 (quoting Michigan v. Tyler, 436 U.S. 499 , 509–510 (1978)). 2016Indeed, the Supreme Court expressed disapproval of per, se exceptions to the warrant requirement and held that “the natural metabolization of alcohol in the bloodstream” did not present a “per se exigency that justifies an exception to the Fourth Amendment’s warrant requirement for non-eonsensual blood testing in all drunk-driving cases.” McNeely , at -, 133 S.Ct. at 1556 , 185 L.Ed.2d at 702 . | 2 | 2016–2022 |
State v. Daniel Chernobieff
green
2 sentences2021The ringer testimony, although indicative of a concerning 6 breakdown in the after-hours warrant application process in Ada County at the time of Chernobieff’s arrest, see Chernobieff I, 161 Idaho at 541 , 387 P.3d at 794 , is of no consequence to the exigent circumstances analysis. 2021The ringer testimony, although indicative of a concerning 6 breakdown in the after-hours warrant application process in Ada County at the time of Chernobieff’s arrest, see Chernobieff I, 161 Idaho at 541 , 387 P.3d at 794 , is of no consequence to the exigent circumstances analysis. | 2 | 2021–2022 |
State v. Reynolds
green
2 sentences2012Michigan v. Tyler, 436 U.S. 499, 509 (1978); Reynolds, 146 Idaho at 470 , 197 P.3d at 331 . 2012Michigan v. Tyler, 436 U.S. 499, 509 (1978); Reynolds, 146 Idaho at 470 , 197 P.3d at 331 . | 2 | 2009–2012 |
Chernobieff v. State
green
1 sentence2022In Chernobieff II, we disavowed the good-cause statement in Chernobieff I as dicta, but we reiterated our admonition that “it is the responsibility of the trial courts to provide a reliable and effective system for warrant applications ‘both during regular office hours and through the night and on weekends.’ ” Chernobieff II, 168 Idaho at 104, 480 P.3d at 142 (quoting Chernobieff I, 161 Idaho at 541 , 387 P.3d at 794 ). | 1 | 2022–2022 |
State v. Smith
green
2 sentences2021Smith, 144 Idaho at 485–86, 163 P.3d at 1197–98. 2021Smith, 144 Idaho at 485–86, 163 P.3d at 1197–98. | 1 | 2021–2021 |
State v. Curl
green
2 sentences2020Nonetheless, the gravity of the offense remains an important factor in assessing the exigent circumstances exception to the warrant requirement, as “[p]reventing someone from disposing of or hiding a murdered corpse is clearly much more of an emergency than keeping someone from flushing a few ounces of marijuana or other controlled substances down a toilet.” Curl, 125 Idaho at 225 n.1, 869 P.2d at 225 n.1. 2020Nonetheless, the gravity of the offense remains an important factor in assessing the exigent circumstances exception to the warrant requirement, as “[p]reventing someone from disposing of or hiding a murdered corpse is clearly much more of an emergency than keeping someone from flushing a few ounces of marijuana or other controlled substances down a toilet.” Curl, 125 Idaho at 225 n.1, 869 P.2d at 225 n.1. | 1 | 2020–2020 |
State v. Rodriguez
green
2 sentences2008See Diaz, 144 Idaho 300 , 160 P.3d 739 ; State v. Rodriguez, 128 Idaho 521 , 915 P.2d 1379 (Ct.App.1996). 2008See Diaz, 144 Idaho 300 , 160 P.3d 739 ; State v. Rodriguez, 128 Idaho 521 , 915 P.2d 1379 (Ct.App.1996). | 1 | 2008–2008 |
| Colten v. Kentucky green | 1 | 2006–2006 |
| State v. Buterbaugh green | 1 | 2006–2006 |
| Schmerber v. California green | 1 | 2002–2002 |
| Warden, Maryland Penitentiary v. Hayden green | 1 | 1999–1999 |
| State v. Koziol green | 1 | 1989–1989 |
| State v. Blake green | 1 | 1989–1989 |
| State v. Niedermeyer green | 1 | 1989–1989 |
| Gasset v. State green | 1 | 1989–1989 |
| M/G Transport Services, Inc. v. Citizens Fidelity Bank & Trust Co. green | 1 | 1989–1989 |
| Williamson v. Kimbrough green | 1 | 1989–1989 |
| First National Bank v. Marquette National Bank green | 1 | 1989–1989 |
| Ker v. California green | 1 | 1978–1978 |
| People v. Maddox green | 1 | 1978–1978 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.