exigent circumstances exception (North Dakota) · Go Syfert
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exigent circumstances exception in North Dakota

18 North Dakota opinions name it 1 courts 1984–2019 0 in the last five years

The cases below were cited by North Dakota 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.

Followed or applied (14)

CaseFollowedCited
Missouri v. McNeelygreen
scotus · 2013 · cited in 3 North Dakota opinions naming this issue, 2015–2018
2 sentences

2015TV [¶ 9] Morales argues the district court erred in ruling the exigent circumstances exception to the warrant requirement permitted the warrantless blood draw. [¶ 10] Exigent circumstances are “an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to fore *421 stall the imminent escape of a suspect or destruction of evidence.” DeCoteau, 1999 ND 77, ¶ 15 , 592 N.W.2d 579 (quoting City of Fargo v. Lee, 1998 ND 126, ¶ 10 , 580 N.W.2d 580 ). [¶ 11] In Missouri v. McNeely, — U.S. -, 133 S.Ct. 1552, 1558-59 , 185 L.Ed.2d 696 (2013) (citati

2015TV [¶ 9] Morales argues the district court erred in ruling the exigent circumstances exception to the warrant requirement permitted the warrantless blood draw. [¶ 10] Exigent circumstances are “an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to fore *421 stall the imminent escape of a suspect or destruction of evidence.” DeCoteau, 1999 ND 77, ¶ 15 , 592 N.W.2d 579 (quoting City of Fargo v. Lee, 1998 ND 126, ¶ 10 , 580 N.W.2d 580 ). [¶ 11] In Missouri v. McNeely, — U.S. -, 133 S.Ct. 1552, 1558-59 , 185 L.Ed.2d 696 (2013) (citati

13
State v. Ackermangreen
nd · 1993 · cited in 2 North Dakota opinions naming this issue, 1997–2013
2 sentences

2013See State v. Ackerman, 499 N.W.2d 882, 886 (N.D.1993).

2013See State v. Ackerman , 499 N.W.2d 882, 886 (N.D. 1993).

12
State v. Planzgreen
nd · 1981 · cited in 2 North Dakota opinions naming this issue, 1984–1998
2 sentences

1998In other words, an officer with a plain view of contraband which gives rise to probable cause is not immunized from our rule that a “warrantless search and seizure is unreasonable unless it falls within one of the exceptions to the constitutional requirement that a search be conducted pursuant to a valid search warrant.” State v. Koskela, 329 N.W.2d 587, 591 (N.D.1983). [¶ 17] Yet, in Planz we found an exception to the exigent circumstances requirement where the evidence to be seized is “displayed in a manner that does not afford it a reasonable expectation of privacy and it is the instrumenta

1984In State v. Planz, supra, at 81-82, we found an exception to the exigent circumstances requirement when the evidence seized is displayed in a manner that does not afford it a reasonable expectation of privacy and it is the instrumentality of the crime for which the defendant is arrested.

12
Kentucky v. Kinggreen
scotus · 2011 · cited in 1 North Dakota opinions naming this issue, 2018–2018
2 sentences

2018"Recognized exceptions include: consensual searches, stop and frisk searches, hot pursuit , border searches, and airport and courthouse searches." Seglen , at ¶ 7 (emphasis added); see, e.g. , Birchfield v. North Dakota , --- U.S. ----, 136 S.Ct. 2160 , 2173, 195 L.Ed.2d 560 (2016) ("[The exigent circumstances exception] permits, for instance, the warrantless entry of private property when there is a need to provide urgent aid to those inside, when police are in hot pursuit of a fleeing suspect, and when police fear the imminent destruction of evidence.") (citing Kentucky v. King , 563 U.S. 45

2018"Recognized exceptions include: consensual searches, stop and frisk searches, hot pursuit , border searches, and airport and courthouse searches." Seglen , at ¶ 7 (emphasis added); see, e.g. , Birchfield v. North Dakota , --- U.S. ----, 136 S.Ct. 2160 , 2173, 195 L.Ed.2d 560 (2016) ("[The exigent circumstances exception] permits, for instance, the warrantless entry of private property when there is a need to provide urgent aid to those inside, when police are in hot pursuit of a fleeing suspect, and when police fear the imminent destruction of evidence.") (citing Kentucky v. King , 563 U.S. 45

11
Birchfield v. N. Dakota. William Robert Bernardgreen
scotus · 2016 · cited in 1 North Dakota opinions naming this issue, 2018–2018
2 sentences

2018"Recognized exceptions include: consensual searches, stop and frisk searches, hot pursuit , border searches, and airport and courthouse searches." Seglen , at ¶ 7 (emphasis added); see, e.g. , Birchfield v. North Dakota , --- U.S. ----, 136 S.Ct. 2160 , 2173, 195 L.Ed.2d 560 (2016) ("[The exigent circumstances exception] permits, for instance, the warrantless entry of private property when there is a need to provide urgent aid to those inside, when police are in hot pursuit of a fleeing suspect, and when police fear the imminent destruction of evidence.") (citing Kentucky v. King , 563 U.S. 45

2018"Recognized exceptions include: consensual searches, stop and frisk searches, hot pursuit , border searches, and airport and courthouse searches." Seglen , at ¶ 7 (emphasis added); see, e.g. , Birchfield v. North Dakota , --- U.S. ----, 136 S.Ct. 2160 , 2173, 195 L.Ed.2d 560 (2016) ("[The exigent circumstances exception] permits, for instance, the warrantless entry of private property when there is a need to provide urgent aid to those inside, when police are in hot pursuit of a fleeing suspect, and when police fear the imminent destruction of evidence.") (citing Kentucky v. King , 563 U.S. 45

11
People v. Mitchellred
ny · 1976 · cited in 1 North Dakota opinions naming this issue, 2017–2017
2 sentences

2017An officer’s belief that an emergency exists “must be grounded in empirical facts rather than subjective feelings.” Matthews , at ¶ 29 (quoting People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609-10 (1976)). [¶12] The exigent circumstances exception normally applies when officers have an urgent need to act and there is no time to get a warrant.

2017An officer’s belief that an emergency exists “must be grounded in empirical facts rather than subjective feelings.” Matthews , at ¶ 29 (quoting People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609-10 (1976)). [¶12] The exigent circumstances exception normally applies when officers have an urgent need to act and there is no time to get a warrant.

11
City of Fargo v. Stutliengreen
nd · 1993 · cited in 1 North Dakota opinions naming this issue, 2015–2015
1 sentence

2015See City of Fargo v. Stutlien, 505 N.W.2d 738, 741-42 (N.D.1993) (refraining from deciding constitutional issue if case can be decided on appropriate alternative ground).

11
United States v. Jerry Lee Cunninghamgreen
ca8 · 1998 · cited in 1 North Dakota opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir. 1998), cert. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir.1998), ce rt. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

11
United States v. Clarence Richardson, Jr.green
ca7 · 2000 · cited in 1 North Dakota opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir. 1998), cert. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir.1998), ce rt. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

11
Bunn v. United Statesgreen
scotus · 1998 · cited in 1 North Dakota opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir. 1998), cert. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir.1998), ce rt. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

11
Liporace v. United Statesgreen
scotus · 1998 · cited in 1 North Dakota opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir. 1998), cert. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

2003See, e.g., United States v. Cunningham, 133 F.3d 1070, 1072-73 (8th Cir.1998), ce rt. denied, 523 U.S. 1131 , 118 S.Ct. 1823 , 140 L.Ed.2d 960 (1998); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000).

11
Olmstead v. First Interstate Bank of Fargo, N.A.green
nd · 1989 · cited in 1 North Dakota opinions naming this issue, 2002–2002
1 sentence

2002While expressing no opinion on whether exigent circumstances existed, “[ijssues not briefed or argued are deemed abandoned.” Olmstead v. First Interstate Bank of Fargo, N.A., 449 N.W.2d 804, 807 (N.D.1989).

11
State v. Gronlundgreen
nd · 1984 · cited in 1 North Dakota opinions naming this issue, 1998–1998
1 sentence

1998In other words, an officer with a plain view of contraband which gives rise to probable cause is not immunized from our rule that a “warrantless search and seizure is unreasonable unless it falls within one of the exceptions to the constitutional requirement that a search be conducted pursuant to a valid search warrant.” State v. Koskela, 329 N.W.2d 587, 591 (N.D.1983). [¶ 17] Yet, in Planz we found an exception to the exigent circumstances requirement where the evidence to be seized is “displayed in a manner that does not afford it a reasonable expectation of privacy and it is the instrumenta

11
State v. Koskelagreen
nd · 1983 · cited in 1 North Dakota opinions naming this issue, 1998–1998
1 sentence

1998In other words, an officer with a plain view of contraband which gives rise to probable cause is not immunized from our rule that a “warrantless search and seizure is unreasonable unless it falls within one of the exceptions to the constitutional requirement that a search be conducted pursuant to a valid search warrant.” State v. Koskela, 329 N.W.2d 587, 591 (N.D.1983). [¶ 17] Yet, in Planz we found an exception to the exigent circumstances requirement where the evidence to be seized is “displayed in a manner that does not afford it a reasonable expectation of privacy and it is the instrumenta

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Dakota. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
City of Fargo v. Lee green
nd · 1998
2 sentences

2015TV [¶ 9] Morales argues the district court erred in ruling the exigent circumstances exception to the warrant requirement permitted the warrantless blood draw. [¶ 10] Exigent circumstances are “an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to fore *421 stall the imminent escape of a suspect or destruction of evidence.” DeCoteau, 1999 ND 77, ¶ 15 , 592 N.W.2d 579 (quoting City of Fargo v. Lee, 1998 ND 126, ¶ 10 , 580 N.W.2d 580 ). [¶ 11] In Missouri v. McNeely, — U.S. -, 133 S.Ct. 1552, 1558-59 , 185 L.Ed.2d 696 (2013) (citati

2015TV [¶ 9] Morales argues the district court erred in ruling the exigent circumstances exception to the warrant requirement permitted the warrantless blood draw. [¶ 10] Exigent circumstances are “an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to fore *421 stall the imminent escape of a suspect or destruction of evidence.” DeCoteau, 1999 ND 77, ¶ 15 , 592 N.W.2d 579 (quoting City of Fargo v. Lee, 1998 ND 126, ¶ 10 , 580 N.W.2d 580 ). [¶ 11] In Missouri v. McNeely, — U.S. -, 133 S.Ct. 1552, 1558-59 , 185 L.Ed.2d 696 (2013) (citati

32000–2015
Welsh v. Wisconsin green
scotus · 1984
2 sentences

2000The trial court rejected this on the basis of Lee in which we held probable cause to believe minors were illegally consuming alcohol was a relatively minor infraction and did not create exigent circumstances to justify a warrantless entry into a home. 1998 ND 126, ¶ 13 , 580 N.W.2d 580 (relying on Welsh , 466 U.S. at 753 , “application of the exigent circumstances exception in the context of a home entry should rarely be sanctioned when there is probable cause to believe that only a minor offense . . . has been committed.”). [¶17] However, the trial court did find the exigent circumstances of

2000The trial court rejected this on the basis of Lee in which we held probable cause to believe minors were illegally consuming alcohol was a relatively minor infraction and did not create exigent circumstances to justify a warrantless entry into a home. 1998 ND 126, ¶ 13 , 580 N.W.2d 580 (relying on Welsh, 466 U.S. at 753 , 104 S.Ct. 2091 , “application of the exigent circumstances exception in the context of a home entry should rarely be sanctioned when there is probable cause to believe that only a minor offense ... has been committed.”). [¶ 17] However, the trial court did find the exigent ci

31998–2000
State v. Nelson neutral
nd · 2005
2 sentences

2011State v. Nelson, 2005 ND 11, ¶ 11 , 691 N.W.2d 218 .

2011State v. Nelson , 2005 ND 11, ¶ 11 , 691 N.W.2d 218 .

22011–2011
State v. Kitchen green
nd · 1998
2 sentences

2011Id. [¶ 13] An exigent circumstances analysis is analogous to applying the emergency exception.

2011Id. [¶13] An exigent circumstances analysis is analogous to applying the emergency exception.

22011–2011
State v. Nelson green
nd · 2005
2 sentences

2011State v. Nelson, 2005 ND 11, ¶ 11 , 691 N.W.2d 218 .

2011State v. Nelson , 2005 ND 11, ¶ 11 , 691 N.W.2d 218 .

22011–2011
State v. Mitzel green
nd · 2004
2 sentences

2005However, the trial court incorrectly concluded that because the officers were legally inside, the emergency exception could not apply. [¶11] In State v. Mitzel , 2004 ND 157 , 685 N.W.2d 120 , we analyzed whether the exigent circumstances exception to the warrant requirement applied when a police officer was already inside a residence.

2005However, the trial court incorrectly concluded that because the officers were legally inside, the emergency exception could not apply. [¶11] In State v. Mitzel , 2004 ND 157 , 685 N.W.2d 120 , we analyzed whether the exigent circumstances exception to the warrant requirement applied when a police officer was already inside a residence.

22005–2005
Arizona v. Hicks green
scotus · 1987
1 sentence

2019Id. at 323 .

12019–2019
State v. Morales green
nd · 2015
2 sentences

2017State v. Morales , 2015 ND 230, ¶ 11 , 869 N.W.2d 417 (citing Missouri v. McNeely , 133 S. Ct. 1552, 1558-59 (2013)).

2017State v. Morales, 2015 ND 230, ¶ 11 , 869 N.W,2d 417 (citing Missouri v. McNeely, 569 U.S. 141 , 133 S.Ct. 1552, 1558-59 , 185 L.Ed.2d 696 (2013)).

12017–2017
State v. DeCoteau green
nd · 1999
2 sentences

2015TV [¶ 9] Morales argues the district court erred in ruling the exigent circumstances exception to the warrant requirement permitted the warrantless blood draw. [¶ 10] Exigent circumstances are “an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to fore *421 stall the imminent escape of a suspect or destruction of evidence.” DeCoteau, 1999 ND 77, ¶ 15 , 592 N.W.2d 579 (quoting City of Fargo v. Lee, 1998 ND 126, ¶ 10 , 580 N.W.2d 580 ). [¶ 11] In Missouri v. McNeely, — U.S. -, 133 S.Ct. 1552, 1558-59 , 185 L.Ed.2d 696 (2013) (citati

2015TV [¶ 9] Morales argues the district court erred in ruling the exigent circumstances exception to the warrant requirement permitted the warrantless blood draw. [¶ 10] Exigent circumstances are “an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to fore *421 stall the imminent escape of a suspect or destruction of evidence.” DeCoteau, 1999 ND 77, ¶ 15 , 592 N.W.2d 579 (quoting City of Fargo v. Lee, 1998 ND 126, ¶ 10 , 580 N.W.2d 580 ). [¶ 11] In Missouri v. McNeely, — U.S. -, 133 S.Ct. 1552, 1558-59 , 185 L.Ed.2d 696 (2013) (citati

12015–2015
People v. Bondi green
illappct · 1984
2 sentences

2003Id. [¶ 38] The guidelines in Mitchell , as well as the holdings announced in Chaney, 612 P.2d 269 , Bondi, 130 Ill.App.3d 536 , 85 Ill.Dec. 773 , 474 N.E.2d 733 , and Oliver, 656 A.2d 1159 , fully apply in the instant case, justifying the emergency exception under the exigent circumstances doctrine and allowing the officers to enter the Matthews residence without a warrant. [¶ 39] The investigating officer, Sergeant Pallas, and the other officers had a justifiable reason to believe that an emergency existed.

2003Id. [¶ 38] The guidelines in Mitchell , as well as the holdings announced in Chaney, 612 P.2d 269 , Bondi, 130 Ill.App.3d 536 , 85 Ill.Dec. 773 , 474 N.E.2d 733 , and Oliver, 656 A.2d 1159 , fully apply in the instant case, justifying the emergency exception under the exigent circumstances doctrine and allowing the officers to enter the Matthews residence without a warrant. [¶ 39] The investigating officer, Sergeant Pallas, and the other officers had a justifiable reason to believe that an emergency existed.

12003–2003
Chaney v. State green
oklacrimapp · 1980
2 sentences

2003Id. [¶ 38] The guidelines in Mitchell , as well as the holdings announced in Chaney, 612 P.2d 269 , Bondi, 130 Ill.App.3d 536 , 85 Ill.Dec. 773 , 474 N.E.2d 733 , and Oliver, 656 A.2d 1159 , fully apply in the instant case, justifying the emergency exception under the exigent circumstances doctrine and allowing the officers to enter the Matthews residence without a warrant. [¶ 39] The investigating officer, Sergeant Pallas, and the other officers had a justifiable reason to believe that an emergency existed.

2003Id. [¶ 38] The guidelines in Mitchell , as well as the holdings announced in Chaney, 612 P.2d 269 , Bondi, 130 Ill.App.3d 536 , 85 Ill.Dec. 773 , 474 N.E.2d 733 , and Oliver, 656 A.2d 1159 , fully apply in the instant case, justifying the emergency exception under the exigent circumstances doctrine and allowing the officers to enter the Matthews residence without a warrant. [¶ 39] The investigating officer, Sergeant Pallas, and the other officers had a justifiable reason to believe that an emergency existed.

12003–2003
Oliver v. United States green
dc · 1995
2 sentences

2003Id. [¶ 38] The guidelines in Mitchell , as well as the holdings announced in Chaney, 612 P.2d 269 , Bondi, 130 Ill.App.3d 536 , 85 Ill.Dec. 773 , 474 N.E.2d 733 , and Oliver, 656 A.2d 1159 , fully apply in the instant case, justifying the emergency exception under the exigent circumstances doctrine and allowing the officers to enter the Matthews residence without a warrant. [¶ 39] The investigating officer, Sergeant Pallas, and the other officers had a justifiable reason to believe that an emergency existed.

2003Id. [¶ 38] The guidelines in Mitchell , as well as the holdings announced in Chaney, 612 P.2d 269 , Bondi, 130 Ill.App.3d 536 , 85 Ill.Dec. 773 , 474 N.E.2d 733 , and Oliver, 656 A.2d 1159 , fully apply in the instant case, justifying the emergency exception under the exigent circumstances doctrine and allowing the officers to enter the Matthews residence without a warrant. [¶ 39] The investigating officer, Sergeant Pallas, and the other officers had a justifiable reason to believe that an emergency existed.

12003–2003

Statutes the citing opinions construe

ND § N.D. Cent. Code § 29-28-06 (6) ND § N.D. Cent. Code § 27-05-06 (4)

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.

Where else courts name it

TX 133 (1975–2025) PA 115 (1974–2026) OH 106 (1978–2025) CA 82 (1977–2026) WA 71 (1973–2022) NJ 57 (1970–2026) WI 54 (1982–2026) IL 50 (1977–2025) IA 46 (1977–2025) MI 45 (1981–2025) OR 41 (1972–2021) CO 41 (1977–2026) FL 40 (1981–2024) NM 35 (1975–2022) VA 34 (1992–2026) ID 33 (1978–2026) MN 31 (1984–2025) NY 31 (1973–2024) TN 28 (1996–2020) IN 28 (1985–2025) SC 24 (1986–2023) MO 23 (1985–2019) CT 23 (1978–2023) ME 22 (1974–2024) UT 19 (1991–2025) ND 18 (1984–2019) LA 18 (1981–2026) DC 17 (1976–2018) GA 17 (1975–2026) KS 16 (1990–2022) MD 15 (1973–2026) MA 15 (1975–2025) NH 14 (1974–2018) AZ 13 (1984–2018) AL 13 (1976–2015) NC 13 (1983–2024) MT 13 (1996–2024) DE 11 (1974–2026) SD 11 (1978–2021) RI 10 (1983–2025) WV 9 (1985–2023) KY 9 (1979–2025) AR 7 (1992–2005) NV 7 (1989–2025) HI 6 (1981–2002) AK 5 (1993–2009) VT 5 (1982–2023) MS 4 (1997–2017) VI 2 (1984–2012) WY 2 (1987–2017) NE 2 (2015–2024)

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.

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