emergency aid exception in Minnesota

2026Thus, for purposes of the Fourth Amendment, a warrantless search or seizure may be valid under the emergency-aid exception when (1) police “have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property” and (2) there is “some reasonable basis, 13 approximating probable cause, to associate the emergency with the area or place to be searched.” Id. at 632 (quoting State v. Lemieux, 726 N.W.2d 783, 788 (Minn. 2007)). 5 Of particular relevance here, the subjective motivation of the officer is irrelevant to the

2026See Brigham City v. Stuart, 547 U.S. 398, 404 (2006) (holding that, under the emergency-aid exception to the Fourth Amendment’s warrant requirement, “[t]he officer’s subjective motivation is irrelevant”); Ries, 920 N.W.2d at 632 n.6 (acknowledging Lemieux’s reference to “the prior application of an additional prong” requiring that the officer “must not be primarily motivated by the intent to arrest and seize evidence,” but recognizing that Brigham City rejected that prong for Fourth Amendment purposes); Lemieux, 726 N.W.2d at 788 (stating that, under Brigham City, an officer’s subjective inten

2026See Brigham City v. Stuart, 547 U.S. 398, 404 (2006) (holding that, under the emergency-aid exception to the Fourth Amendment’s warrant requirement, “[t]he officer’s subjective motivation is irrelevant”); Ries, 920 N.W.2d at 632 n.6 (acknowledging Lemieux’s reference to “the prior application of an additional prong” requiring that the officer “must not be primarily motivated by the intent to arrest and seize evidence,” but recognizing that Brigham City rejected that prong for Fourth Amendment purposes); Lemieux, 726 N.W.2d at 788 (stating that, under Brigham City, an officer’s subjective inten

2018The Supreme Court recognized the emergency-aid exception in Brigham City v. Stuart , 547 U.S. 398 , 126 S.Ct. 1943 , 164 L.Ed.2d 650 (2006).

2026See Ries, 920 N.W.2d at 632 (“Under the emergency-aid exception, officers may help an injured person or act to protect life or property if” they have “reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property.” (quotation omitted)); State v. Othoudt, 482 N.W.2d 218, 223 (Minn. 1992) (stating that, “[t]o determine whether the officer’s actions meet an objective standard of reasonableness [for purposes of the emergency-aid exception] the court should ask whether with the facts available to the officer at the

2016It held that Stemme and Rehling’s observations “reasonably led the officers to be concerned that there may be a burglary in progress or a medical emergency.” The district court further determined that “the officers would have been derelict in their duty had they not entered the home” and their “decision to enter the home without a warrant was reasonable.” We “independently review the facts and determine, as a matter of law, whether the evidence need be suppressed.” State v. Othoudt, 482 N.W.2d 218, 221 (Minn. 1992).

2007It cannot be used as the occasion for a general voyage of discovery unrelated to the purpose of the entry.” United States v. Moss, 963 F.2d 673, 678 (4th Cir.1992) (holding that even if original entry of cabin had been justified under the emergency-aid exception, search of defendant’s backpack for identification was unreasonable).

2007It cannot be used as the occasion for a general voyage of discovery unrelated to the purpose of the entry.” United States v. Moss, 963 F.2d 673, 678 (4th Cir.1992) (holding that even if original entry of cabin had been justified under the emergency-aid exception, search of defendant’s backpack for identification was unreasonable).

2026The emergency-aid exception “is a subset of the exigent-circumstances exception to the warrant requirement” that applies “in circumstances when police are objectively motivated by the need to render aid or prevent injury.” Ries v. State, 920 N.W.2d 620, 631 (Minn. 2018).

2026Thus, for purposes of the Fourth Amendment, a warrantless search or seizure may be valid under the emergency-aid exception when (1) police “have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property” and (2) there is “some reasonable basis, 13 approximating probable cause, to associate the emergency with the area or place to be searched.” Id. at 632 (quoting State v. Lemieux, 726 N.W.2d 783, 788 (Minn. 2007)). 5 Of particular relevance here, the subjective motivation of the officer is irrelevant to the

2026Applying the legal framework argued by the parties, which was based on this court’s decision in State v. Lopez, the district court found the emergency-aid exception was satisfied because the officer was subjectively motivated by concern for Gale’s well-being and because a reasonable person would believe that an emergency existed. 698 N.W.2d 18, 23 (Minn. App. 2005).

2026See Ries, 920 N.W.2d at 632 (“Under the emergency-aid exception, officers may help an injured person or act to protect life or property if” they have “reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property.” (quotation omitted)); State v. Othoudt, 482 N.W.2d 218, 223 (Minn. 1992) (stating that, “[t]o determine whether the officer’s actions meet an objective standard of reasonableness [for purposes of the emergency-aid exception] the court should ask whether with the facts available to the officer at the

2016Lemieux relied on the reasoning of other courts that had “concluded that police entry is justifiable under the emergency-aid exception where police have reasonable grounds to believe that a burglary is in progress or has recently occurred.” Id. at 789 (citing, among others, Murdock v. Stout, 54 F.3d 1437 , 1441–42 (9th Cir. 1995) (upholding warrantless entry during investigation of suspected burglary, where facts known to police indicated that resident was not responding and circumstances suggested that resident should have been present), and Carroll v. State, 646 A.2d 376, 384 (Md. 1994) (uph

2007See, e.g., United States v. Lenoir, 318 F.3d 725, 730-31 (7th Cir.2003) (upholding warrant-less entry where defendant who was carrying two high-powered rifles fled from police into nearby home but had trouble entering the door and police reasonably feared for the safety of the home’s occupants); United States v. Tibolt, 72 F.3d 965, 970-71 (1st Cir.1995) (upholding war-rantless entry on reasonable, though mistaken,' belief that residence was the source of security alarm); Murdock v. Stout, 54 F.3d 1437, 1441-42 (9th Cir.1995) (upholding warrantless entry during investigation of suspected burgl

2026As support for her proposition that Brigham City was a sharp departure from Minnesota’s tradition of considering an officer’s subjective intent in the context of the emergency-aid exception, Gale relies on the supreme court’s decision in State v. Terrell. 283 N.W.2d 529 (Minn. 1979).

2026Viewed in context, we understand Terrell’s statement about the chief deputy’s beliefs to be a reference to the objective component of the emergency-aid exception, which the supreme court explained authorizes a police officer to make “warrantless entries and searches when they reasonably believe that a person within is in need of immediate aid.” Id. (quotation omitted).

2016Lemieux relied on the reasoning of other courts that had “concluded that police entry is justifiable under the emergency-aid exception where police have reasonable grounds to believe that a burglary is in progress or has recently occurred.” Id. at 789 (citing, among others, Murdock v. Stout, 54 F.3d 1437 , 1441–42 (9th Cir. 1995) (upholding warrantless entry during investigation of suspected burglary, where facts known to police indicated that resident was not responding and circumstances suggested that resident should have been present), and Carroll v. State, 646 A.2d 376, 384 (Md. 1994) (uph

2007See, e.g., United States v. Lenoir, 318 F.3d 725, 730-31 (7th Cir.2003) (upholding warrant-less entry where defendant who was carrying two high-powered rifles fled from police into nearby home but had trouble entering the door and police reasonably feared for the safety of the home’s occupants); United States v. Tibolt, 72 F.3d 965, 970-71 (1st Cir.1995) (upholding war-rantless entry on reasonable, though mistaken,' belief that residence was the source of security alarm); Murdock v. Stout, 54 F.3d 1437, 1441-42 (9th Cir.1995) (upholding warrantless entry during investigation of suspected burgl

2026Thus, Lemieux did not settle the question of whether the Minnesota Constitution provided broader protection by considering an officer’s subjective intent under the emergency-aid exception. 16 See City of Golden Valley v. Wiebesick, 899 N.W.2d 152, 157 (Minn. 2017) (rejecting the district court’s conclusion that the Minnesota Supreme Court had previously determined a state constitutional law question related to individualized suspicion for administrative warrants because the prior decision had “only assumed arguendo that individualized suspicion was required for an administrative search warrant

2026Thus, Lemieux did not settle the question of whether the Minnesota Constitution provided broader protection by considering an officer’s subjective intent under the emergency-aid exception. 16 See City of Golden Valley v. Wiebesick, 899 N.W.2d 152, 157 (Minn. 2017) (rejecting the district court’s conclusion that the Minnesota Supreme Court had previously determined a state constitutional law question related to individualized suspicion for administrative warrants because the prior decision had “only assumed arguendo that individualized suspicion was required for an administrative search warrant

2026See Ries, 920 N.W.2d at 632 (“Under the emergency-aid exception, officers may help an injured person or act to protect life or property if” they have “reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property.” (quotation omitted)); State v. Othoudt, 482 N.W.2d 218, 223 (Minn. 1992) (stating that, “[t]o determine whether the officer’s actions meet an objective standard of reasonableness [for purposes of the emergency-aid exception] the court should ask whether with the facts available to the officer at the

2026Minnesota courts have a responsibility to “safeguard for the people of Minnesota the protections embodied in our constitution.” State v. Askerooth, 681 N.W.2d 353, 362 (Minn. 2004).

2026Askerooth, 681 N.W.2d at 362 .

2018See State v. Hannuksela , 452 N.W.2d 668 , 673 n.7 (Minn. 1990) (applying a legal doctrine that the parties failed to argue in their briefs or at oral argument because appellate courts have a responsibility to decide cases in accordance with the law).

2018See , e.g. , United States v. Stafford , 416 F.3d 1068 , 1073 (9th Cir. 2005) (citing Cady but applying the "emergency doctrine"); State v. Deneui , 775 N.W.2d 221 , 237 (S.D. 2009) (discussing "courts [that] apply[ ] the community caretaker exception but us[e] a test applicable to the emergency doctrine or the emergency aid doctrine").

2018See Williams , 771 N.W.2d at 517 n.2 (holding that although the issues in question were properly raised in the petition for review, the defendant forfeited appellate review of the issues when he failed to brief or argue the issues in our court).

2018See id.

2018State v. Ries , 889 N.W.2d 308 , 317 (Minn. App. 2016).

2016The supreme court noted that, because 5 burglary “always carries with it the possibility of violence and therefore some special risks to human life,” State v. Nunn, 297 N.W.2d 752, 754 (Minn. 1980), belief that a burglary may be in progress may justify an officer’s warrantless entry into a home, Lemieux, 726 N.W.2d at 789 .

2016State v. McClain, 862 N.W.2d 717, 721 (Minn. App. 2015).

2015Lemieux, 726 N.W.2d at 788 ; see State v. Fitzgerald, 562 N.W.2d 288, 288 (Minn. 1997) (determining exception did not apply when police had vague understanding that potential victim “may need help”).

2015See Brigham City, Utah v. Stuart, 547 U.S. 398, 406 , 126 S. Ct. 1943, 1949 (2006) (holding that officers lawfully entered a residence after hearing a “tumultuous” altercation, “thumping and crashing,” people yelling “stop, stop” and “get off me,” and after observing one person strike another “in the face, sending the [victim] to the sink spitting blood”); Lemieux, 726 N.W.2d at 789 (holding that officers lawfully entered a residence while investigating a homicide, after being told that someone was in the residence that night and observing that a screen window had been torn, the window was ope

2015See Cnty. of Hennepin v. Law Enforcement Labor Servs., Inc., Local No. 19, 527 N.W.2d 821, 826 (Minn.1995) (stating that facts giving rise to the emergency-aid exception occur in “rare cases”).

2007See also Cervantes, 219 F.3d at 891-92 (holding initial entry of apartment to locate methamphetamine lab under the emergency exception was justified, but subsequent entry by investigator was not, given that “the risk of explosion had been defused”).

2007See, e.g., Cervantes, 219 F.3d at 891 (concluding that officer making war-rantless entry to locate a methamphetamine lab during criminal investigation was primarily motivated by concern for the safety of the apartment building’s occupants, as evidenced by the officer’s order that the tenants turn off open flames and evacuate the building); see also Decker, supra at 511-16 (discussing subjective-motivation element).

2007See, e.g., United States v. Lenoir, 318 F.3d 725, 730-31 (7th Cir.2003) (upholding warrant-less entry where defendant who was carrying two high-powered rifles fled from police into nearby home but had trouble entering the door and police reasonably feared for the safety of the home’s occupants); United States v. Tibolt, 72 F.3d 965, 970-71 (1st Cir.1995) (upholding war-rantless entry on reasonable, though mistaken,' belief that residence was the source of security alarm); Murdock v. Stout, 54 F.3d 1437, 1441-42 (9th Cir.1995) (upholding warrantless entry during investigation of suspected burgl

2007See, e.g., United States v. Lenoir, 318 F.3d 725, 730-31 (7th Cir.2003) (upholding warrantless entry where defendant who was carrying two high-powered rifles fled from police into nearby home but had trouble entering the door and police reasonably feared for the safety of the home's occupants); United States v. Tibolt, 72 F.3d 965, 970-71 (1st Cir.1995) (upholding warrantless entry on reasonable, though mistaken, belief that residence was the source of security alarm); Murdock v. Stout, 54 F.3d 1437, 1441-42 (9th Cir.1995) (upholding warrantless entry during investigation of suspected burglary

2007See, e.g., State v. Carter, 697 N.W.2d 199, 210-11 (Minn.2005) (holding that a tenant has an expectation of privacy in a self-storage unit and suppressing evidence seized in the search without requiring that the defendant be present at the time of the search); State v. Lemieux, 726 N.W.2d 783, 787, 790 (Minn.2007) (holding that the warrantless search was legal because it was justified by the emergency-aid exception, but assuming that the defendant had a reasonable expectation of privacy in “his own abode” despite the fact he was not present during the search). 4 Similarly, where a seizure purs

2007See, e.g., State v. Carter, 697 N.W.2d 199, 210-11 (Minn.2005) (holding that a tenant has an expectation of privacy in a self-storage unit and suppressing evidence seized in the search without requiring that the defendant be present at the time of the search); State v. Lemieux, 726 N.W.2d 783, 787, 790 (Minn.2007) (holding that the warrantless search was legal because it was justified by the emergency-aid exception, but assuming that the defendant had a reasonable expectation of privacy in "his own abode" despite the fact he was *157 not present during the search). [4] Similarly, where a seizu

2007Othoudt, 482 N.W.2d at 223 . 2 In determining whether an emergency justified a warrant-less entry, a number of courts had followed a three-prong test articulated in People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976): (1) The police must have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property. (2) The search must not be primarily motivated by intent to arrest and seize evidence. (3) There must be some reasonable basis, approximating probable cause, to associate the emer

2007Othoudt, 482 N.W.2d at 223 . 2 In determining whether an emergency justified a warrant-less entry, a number of courts had followed a three-prong test articulated in People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976): (1) The police must have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property. (2) The search must not be primarily motivated by intent to arrest and seize evidence. (3) There must be some reasonable basis, approximating probable cause, to associate the emer