The emergency aid exception justified entry into defendant’s house where the officer reasonably feared the owner or occupant of the house was in some sort of danger based upon the front door being wide open in the middle of winter, there were no cars in the driveway, a young dog inside the home was acting really skittish, and there was a large amount of dog feces on the floor. Inside he found a marijuana grow in plain view. State v. Hawkins, 2017-Ohio-715, 2017 Ohio App. LEXIS 708 (7th Dist. Feb. 27, 2017).
Defendant was a passenger in a stopped rental car, and it was apparent to the officer that the two in the car were lying about what was up and where they were going. By the time the drug dog arrived, the officer completed the initial checks, and the officer didn’t do anything really to extend the stop unreasonably. United States v. Angulo, 2017 U.S. Dist. LEXIS 25098 (D.N.J. Feb. 22, 2017).*