“[T]he officers had a reasonable belief based on specific and articulable facts to search for injured people” based on bullet casings in the street and bullet holes in the house even when the waited an hour. They didn’t have to call EMTs first. State v. Parker, 2018-Ohio-3239, 2018 Ohio App. LEXIS 3499 (11th Dist. Aug. 13, 2018):
[*P29] At the time of the initial search, the officers had a reasonable belief based on specific and articulable facts to search for injured people. The officers found multiple bullet casings in the street in front of the home; there were multiple bullet holes in the exterior of the home; the windows of a parked car in the driveway were shot out; and when they knocked on the doors, no one answered.
[*P30] Appellant further argues the lack of urgency because the officers had not called any emergency squads to the scene prior to the search. However, the emergency aid exception does not require knowledge of actual injury, only articulable facts warranting a reasonable belief that someone could be injured and in need. To this extent, there is no requirement to call for medical aid pre-search. Moreover, the presence of the police dogs for later investigation, and a one hour delay do not render their initial entry unlawful.
A one hour delay for searching for injured people still makes this an emergency search. Really? How?