This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Law enforcement officers received a tip from a school bus driver about suspicious vehicular traffic at a residence near a school, suggesting possible drug activity. Upon investigation, officers detected the smell of marijuana from the residence. After knocking on the door, they heard noises inside but were told by the occupant and his son that no one else was present. Despite this, an officer conducted a warrantless sweep of the residence, discovering drug-related items in plain view. A search warrant was later obtained, leading to the seizure of marijuana and related evidence (paras 3-7).
Procedural History
- District Court, San Juan County: Suppressed evidence obtained from the residence, ruling that the warrantless entry was unlawful and that no exigent circumstances justified it. The court also suppressed evidence obtained under the subsequent search warrant, as it was tainted by the prior unlawful entry (paras 1-2).
Parties' Submissions
- State (Appellant): Argued that the warrantless entry was justified to prevent the destruction of evidence. Alternatively, claimed that the search warrant was validly issued based on information obtained prior to the unlawful entry, and thus the evidence should not be suppressed (para 2).
- Defendant (Appellee): Contended that the warrantless entry violated the Fourth Amendment and that the evidence obtained under the search warrant was inadmissible as it was the fruit of the unlawful entry (paras 1-2).
Legal Issues
- Was the warrantless entry of the residence justified by exigent circumstances?
- Should the evidence obtained under the search warrant be admissible under the inevitable-discovery exception to the exclusionary rule?
Disposition
- The Court of Appeals affirmed the district court's ruling that the warrantless entry was unlawful.
- The case was remanded to the district court to determine whether the evidence seized under the search warrant was admissible under the inevitable-discovery exception (paras 26-27).
Reasons
Per Hartz CJ (Alarid and Wechsler JJ. concurring):
Warrantless Entry: The Fourth Amendment requires a warrant for searches unless exigent circumstances exist. The court found no reasonable basis for believing that evidence would be destroyed during the time required to obtain a warrant. The officers had no substantial evidence of a third person in the trailer after the defendant and his son exited, and the absence of noise from the small trailer further supported this conclusion. The officer's conduct, including the lack of urgency and failure to draw his weapon, also indicated no immediate threat (paras 9-22).
Inevitable Discovery: The court acknowledged that the search warrant affidavit contained sufficient information obtained prior to the unlawful entry to establish probable cause. However, it remanded the case to the district court to determine whether the officers would have sought the warrant and whether the magistrate would have issued it without the tainted information. The district court is better positioned to assess the credibility of the officer's testimony and the magistrate's likely decision (paras 23-25).