IA: Runaway drunk suicidal teenager tracked to house was exigent circumstance when no answer at door

Police tracked a suicidal and intoxicated runaway teenager to defendant’s house via the cell phone’s GPS. At the house, nobody responded to the door, but the officers could hear the TV on upstairs. The door opened with a touch, and the lock was broken. The entry was justified by exigent circumstances. State v. York, 829 N.W.2d 191 (Iowa App. 2013):

Guiding our Fourth Amendment analysis is the fundamental question of “whether the search and seizure were reasonable in light of the facts and circumstances of the case.” Crawford, 659 N.W.2d at 542. We must ask whether under the facts known to officers at the time, “a reasonable person would have thought than an emergency existed.” Carlson, 548 N.W.2d at 143. An intoxicated and suicidal teenager led police to a home where they discovered signs of a forced entry and unresponsive residents. Given the juvenile’s suicidal threats following a physical and verbal confrontation with his parents, police officers were justified in fearing for the juvenile’s life. Officers on the scene were not privy to the innocent explanation for the broken door handle nor did they have the benefit of hindsight with the time to make a calculated and technical review of the evidence. While a concerned mother watched as police searched for her intoxicated and suicidal son in near-freezing temperatures, a reasonable person under the circumstances would have thought an emergency existed sufficient to require immediate action. We find the police officers exercised their role as community caretakers in entering the home.