CA11: Interrupted residential burglary is exigency for police entry and search

“Police officers interrupt what they reasonably believe to be a residential burglary and detain two suspects just outside the house. Having done so, can the officers thereafter lawfully enter the home—without a warrant, and without further suspicion of wrongdoing—to briefly search for additional perpetrators and potential victims? We hold that they can. In particular, we hold that the suspected burglary presents an “exigent circumstance” that justifies a warrantless entry and search.” Montanez v. Carvajal, 2018 U.S. App. LEXIS 12146 (11th Cir. May 9, 2018).

Defendant had no reasonable expectation of privacy in a union hall where he was found after a one vehicle accident. State v. Teeple, 2018-Ohio-1767, 2018 Ohio App. LEXIS 1905 (3d Dist. May 7, 2018).

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