emergency exception in District of Columbia

1995In that context, we interpret “probable cause” to mean “reasonable grounds to believe” — a formulation that says what we think the Supreme Court meant by “reasonable belief’ in Mincey, supra, 437 U.S. at 392 , 98 S.Ct. at 2413 ; a formulation that reflects the need for solid facts warranting probable cause, not mere reasonable suspicion (as in Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 , 20 L.Ed.2d 889 (1968)); a formulation that is commonly used to mean probable cause, see 2 W.R.

1995In that context, we interpret “probable cause” to mean “reasonable grounds to believe” — a formulation that says what we think the Supreme Court meant by “reasonable belief’ in Mincey, supra, 437 U.S. at 392 , 98 S.Ct. at 2413 ; a formulation that reflects the need for solid facts warranting probable cause, not mere reasonable suspicion (as in Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 , 20 L.Ed.2d 889 (1968)); a formulation that is commonly used to mean probable cause, see 2 W.R.

2018In that context-where the police knew a crime had been committed, they had a suspect, and the only question was whether the victim, a newborn baby, could be said to be in need of emergency aid so as to justify the police's warrantless entry into the apartment to retrieve him-the court acknowledged that "it is true that this case is unlike the typical emergency exception where blood at the scene, gunshots, or cries for help will give police 'probable cause, based on specific, articulable facts, to believe that immediate entry is necessary to assist someone in danger of bodily harm.' " Id.

2018The court then explained that the departure from this norm was justified by "the unique qualities of kidnapping" which "may create exigent or emergency circumstances, even without direct evidence of a threat of bodily harm to the victim." Id. (explaining that "kidnapping investigations present unusually compelling circumstances for emergency analysis" because "the life, freedom, and future of a human being is at stake" and that *36 kidnapped infants "in particular" are especially vulnerable).

2008Id. at 1082-83 .

1995Where we believe it is important for the sake of accuracy or completeness to base our factual presentation on the record, rather than on the trial court's findings, we do so. [10] Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966). [11] On appeal, the government realized that we might not agree that the emergency exception justified the warrantless entry and seizure.

1995Where we believe it is important for the sake of accuracy or completeness to base our factual presentation on the record, rather than on the trial court's findings, we do so. [10] Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966). [11] On appeal, the government realized that we might not agree that the emergency exception justified the warrantless entry and seizure.

1992A noncustodial father has a “constitutionally protected ‘opportunity interest’ in developing a relationship with his child.” Appeal of H.R., 581 A.2d 1141, 1143 (D.C.1990) (per curiam) (citing Lehr v. Robertson, 463 U.S. 248 , 103 S.Ct. 2985 , 77 L.Ed.2d 614 (1983)).

1992A noncustodial father has a “constitutionally protected ‘opportunity interest’ in developing a relationship with his child.” Appeal of H.R., 581 A.2d 1141, 1143 (D.C.1990) (per curiam) (citing Lehr v. Robertson, 463 U.S. 248 , 103 S.Ct. 2985 , 77 L.Ed.2d 614 (1983)).