emergency aid exception (Colorado) · Go Syfert
← Colorado issues

emergency aid exception in Colorado

8 Colorado opinions name it 2 courts 2002–2015 0 in the last five years

The cases below were cited by Colorado 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 (16)

CaseFollowedCited
People v. Allisongreen
colo · 2004 · cited in 4 Colorado opinions naming this issue, 2004–2015
2 sentences

2015Id. at 426­27. ¶44       To invoke the emergency aid exception, the police must have a reasonable basis approximating probable cause connecting the emergency to the area to be searched.

2015Id. at 426-27 . 144 To invoke the emergency aid exception, the police must have a reasonable basis approximating probable cause connecting the emergency to the area to be searched.

44
People v. Smithgreen
colo · 2002 · cited in 3 Colorado opinions naming this issue, 2002–2005
2 sentences

2005In considering the application of the emergency aid exception, the court “must examine the totality of the circumstances as they would have appeared to a ‘prudent and trained police officer’ at the time the decision to conduct the warrantless search [wa]s made.” Hebert, supra, 46 P.3d at 480 (quoting People v. Smith, 40 P.3d 1287, 1290 (Colo.2002)).

2004However, this is inconsistent with a long line of cases such as Hebert, 46 P.3d at 479 , People v. Smith, 40 P.3d 1287, 1290 (Colo.2002), and People v. Amato, 193 Colo. 57, 60 , 562 P.2d 422, 424 (1977), which require both an immediate crisis and the probability that assistance will be helpful.

33
People v. Hebertgreen
colo · 2002 · cited in 3 Colorado opinions naming this issue, 2003–2005
2 sentences

2005In considering the application of the emergency aid exception, the court “must examine the totality of the circumstances as they would have appeared to a ‘prudent and trained police officer’ at the time the decision to conduct the warrantless search [wa]s made.” Hebert, supra, 46 P.3d at 480 (quoting People v. Smith, 40 P.3d 1287, 1290 (Colo.2002)).

2005In considering the application of the emergency aid exception, the court “must examine the totality of the circumstances as they would have appeared to a ‘prudent and trained police officer’ at the time the decision to conduct the warrantless search [wa]s made.” Hebert, supra, 46 P.3d at 480 (quoting People v. Smith, 40 P.3d 1287, 1290 (Colo.2002)).

23
People v. Kluhsmangreen
colo · 1999 · cited in 2 Colorado opinions naming this issue, 2002–2003
2 sentences

2003Id.; see also Kluhsman, 980 P.2d at 535 n. 7.

2003Id.; see also Kluhsman, 980 P.2d at 535 n. 7.

22
People v. Amatogreen
colo · 1977 · cited in 3 Colorado opinions naming this issue, 2002–2004
2 sentences

2003However, unlike the exigent circumstances exception, the emergency aid exception requires the prosecution to prove the existence of "an immediate crisis and the probability that [police] assistance will be helpful." Amato, 193 Colo. at 60 , 562 P.2d at 424 .

2003However, unlike the exigent circumstances exception, the emergency aid exception requires the prosecution to prove the existence of "an immediate crisis and the probability that [police] assistance will be helpful." Amato, 193 Colo. at 60 , 562 P.2d at 424 .

13
People v. Thompsongreen
colo · 1989 · cited in 2 Colorado opinions naming this issue, 2003–2004
2 sentences

2003Cf. Thompson, 770 P.2d at 1284, 1286 (holding that the police could invoke the emergency aid exception to enter a house without a warrant when the officers observed several spent bullet casings in the driveway; blood all over the outside of the house; the front door ajar several inches; shattered glass in the front door; and the woman answering the door after the police knocked had blood on her face and held an ice pack to her head).

2003Cf. Thompson, 770 P.2d at 1284, 1286 (holding that the police could invoke the emergency aid exception to enter a house without a warrant when the officers observed several spent bullet casings in the driveway; blood all over the outside of the house; the front door ajar several inches; shattered glass in the front door; and the woman answering the door after the police knocked had blood *1014 on her face and held an ice pack to her head).

12
Mendez v. Peoplegreen
colo · 1999 · cited in 1 Colorado opinions naming this issue, 2015–2015
1 sentence

2015See id. 1148 Nor am I persuaded by the People's argument that the emergency aid exception applies here.

11
People v. Reynoldsgreen
colo · 1983 · cited in 1 Colorado opinions naming this issue, 2004–2004
2 sentences

2004People v. Hebert, 46 P.3d 473, 478-79 (Colo.2002); People v. Reynolds, 672 P.2d 529, 531 (Colo.1983).

2004Reynolds, 672 P.2d at 532 .

11
People v. Higbeegreen
colo · 1990 · cited in 1 Colorado opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., People v. Winpigler, 8 P.3d 439, 444 (Colo.1999); People v. Kluhsman, 980 P.2d 529, 534 (Colo.1999); People v. Higbee, 802 P.2d 1085, 1088 (Colo.1990).

11
People v. Winpiglergreen
colo · 1999 · cited in 1 Colorado opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., People v. Winpigler, 8 P.3d 439, 444 (Colo.1999); People v. Kluhsman, 980 P.2d 529, 534 (Colo.1999); People v. Higbee, 802 P.2d 1085, 1088 (Colo.1990).

11
Lubenow v. North Dakota State Highway Commissionergreen
nd · 1989 · cited in 1 Colorado opinions naming this issue, 2002–2002
1 sentence

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

11
State v. Plantgreen
neb · 1990 · cited in 1 Colorado opinions naming this issue, 2002–2002
2 sentences

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

11
State v. Burlisongreen
neb · 1998 · cited in 1 Colorado opinions naming this issue, 2002–2002
2 sentences

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

11
People v. Harpergreen
colo · 1995 · cited in 1 Colorado opinions naming this issue, 2002–2002
1 sentence

2002Smith, 40 P.3d at 1290 ; People v. Harper, 902 P.2d 842, 845 (Colo.1995).

11
State v. Fishergreen
ariz · 1984 · cited in 1 Colorado opinions naming this issue, 2002–2002
2 sentences

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

11
People v. Mitchellred
ny · 1976 · cited in 1 Colorado opinions naming this issue, 2002–2002
2 sentences

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

2002See State v. Fisher, 141 Ariz. 227 , 686 P.2d 750, 760-61 (1984), overruled in part on other grounds by State v. Burlison, 255 Neb. 190 , 583 N.W.2d 31 (1998); State v. Plant, 236 Neb. 317 , 461 N.W.2d 253, 262 (1990); People v. Mitchell, 39 N.Y.2d 173 , 383 N.Y.S.2d 246 , 347 N.E.2d 607, 609 (1976); Lubenow v. North Dakota State Highway Comm'r, 438 N.W.2d 528, 533 (N.D.1989); see also 3 Lafave, supra, § 6.6(a) at 393.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
People v. Pate green
colo · 2003
2 sentences

2004Under the emergency aid exception, the prosecution must prove that both an immediate crisis existed and the probability that assistance will be helpful. 3 Pate, 71 P.3d at 1011 ; Hebert, 46 P.3d at 479 .

2004In Pate , we stated that either of these factors "would be sufficient to invoke the emergency aid exception.” Pate, 71 P.3d at 1013 .

12004–2004

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 16-12-102 (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

OR 61 (1988–2026) NJ 47 (1994–2026) OH 38 (2008–2025) IA 34 (1996–2025) WA 28 (2001–2024) CA 24 (1999–2025) PA 22 (2013–2026) MI 21 (1993–2026) MA 20 (2009–2025) IL 15 (2012–2023) TX 14 (2003–2026) KS 13 (2004–2026) MN 13 (2007–2026) NM 13 (2001–2022) UT 12 (2000–2024) AZ 11 (1984–2024) VA 10 (2002–2024) AK 9 (1979–2018) WI 8 (2021–2025) KY 8 (2011–2020) CO 8 (2002–2015) IN 7 (2016–2026) MD 6 (1996–2013) NH 5 (2001–2020) NY 5 (2012–2024) CT 4 (2022–2024) WY 4 (2004–2020) FL 3 (1980–2017) ME 3 (2021–2024) DC 2 (2016–2018) TN 2 (2008–2013) ID 2 (2003–2013) SC 2 (2020–2020) SD 2 (2009–2021) AR 2 (2010–2021)

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.

← Caselaw search · G Cite Topics · Brief Check