PA: Dead body in defendant’s car + blood stains on his sidewalk + faint voice inside = exigent circumstances

Finding a dead body in defendant’s vehicle was reason to go to defendant’s house. There the officers found blood on the sidewalk and on a broom on the sidewalk. Officers went to the door and heard a faint voice inside. There were exigent circumstances for the entry, and PC for the search warrant issued thereafter. [Note: This is not even a close call.] Commonwealth v. Galvin, 603 Pa. 625, 985 A.2d 783 (2009), cert. denied 176 L. Ed. 2d 565 (U.S. 2010):

Here, the affidavits of probable cause offered in support of the search warrant provided a description of the police observing Appellant driving the van at night without its headlights illuminated, the stopping of the van, the observation, in plain view, of Kolesnik’s body, which was covered in a tarp which was wrapped with electrical wire, and on which there was blood. Additionally, the affidavits contained the officers’ observations of blood on Appellant’s leg, wrist watch, and glasses. The affidavits also contained the police officers’ observations of fresh blood leading from the front door of Appellant’s residence to the sidewalk, and a blood-covered broom on the sidewalk. Moreover, the affidavits described the officers’ approach to the door to determine if persons were in need of emergency treatment, the hearing of a faint voice, and the officers’ entry into the residence. Finally, the affidavits described the officers’ search for persons within the residence, and the observations of the officers once inside the residence. Specifically, the affidavits referenced the officers’ observation of a fresh pool of blood on the carpet next to the bed and an expended bullet shell casing on the floor next to the bed.

Video of defendant’s stop supported it—her car was weaving and the taillight was out. State v. Mercer, 2009 Tenn. Crim. App. LEXIS 1041 (December 22, 2009).*

Officers testified that the defendant consented, but he testified he told them to leave. Officers’ testimony credited and binding. State v. Simonton, 2009 Tenn. Crim. App. LEXIS 1062 (December 29, 2009).*