Officers had sufficient information under Payton that a woman for whom they had a warrant was on the premises she was supposedly living at when they entered. They’d seen her there, and CIs put her there. United States v. Essex, 2022 U.S. App. LEXIS 31947 (6th Cir. Nov. 18, 2022).
Defendant calls this an inventory search, but it was valid under the automobile exception. State v. Graves, 2022-Ohio-4130, 2022 Ohio App. LEXIS 3901 (5th Dist. Nov. 17, 2022).*
Exigency here permitted a warrantless entry. “Here, the district court did not err in determining that reasonable officers would have believed that an exigency justifying an immediate, warrantless entry existed. Although none of these circumstances individually justify a warrantless entry, taken together, the 911 call, Osborne’s statement on the scene, and Vilic’s observations of Arnold and the state of the apartment indicated that Vilic and Jenkins needed to respond swiftly to prevent Goins from harming Arnold.” United States v. Goins, 2022 U.S. App. LEXIS 31948 (6th Cir. Nov. 18, 2022).*