WA: Officers saw a bloody woman through a motel room door and could enter to render emergency aid without a warrant

Police officers went to a motel and scanned the guest registry [a practice later held violated the state constitution] finding a name there was an arrest warrant for. They went to the room and knocked with the intention of arresting. Inside they could see a bloodied woman, and they entered to render aid. Inside they found another girl who said she’d been raped by the defendant. The emergency aid doctrine justified the entry. State v. Smith, 177 Wn.2d 533, 303 P.3d 1047 (2013):

When officers ran the names in a motel registry to check for warrants, they found an outstanding arrest warrant for motel guest Christopher Smith. As they apprehended Smith at the threshold of his motel room, they saw Quianna Quabner, bloodied and limping, inside the room. Officers entered the room and learned that Quabner and her 12-year-old daughter, L.S., had been assaulted in the hours preceding the officers’ arrival; L.S. alleged she had been raped. An immediate investigation ensued, resulting in charges against Smith. Before the case went to trial, however, this court invalidated the practice of random motel registry searches under article I, section 7. State v. Jorden, 160 Wn.2d 121, 156 P.3d 893 (2007).

¶2 At a suppression hearing, Smith argued that the evidence supporting the charges against him was fruit of the unlawful registry search and must be suppressed. The trial court allowed the evidence under the inevitable discovery doctrine, which we later invalidated in State v. Winterstein, 167 Wn.2d 620, 220 P.3d 1226 (2009). On appeal, the Court of Appeals nonetheless upheld Smith’s convictions, concluding the evidence against him was admissible under the attenuation doctrine and the independent source doctrine. The court also rejected Smith’s claim that his convictions for first degree rape and second degree rape of a child, arising from his assault against L.S., violate double jeopardy.

¶3 We affirm the conviction, though on different grounds than the Court of Appeals. We hold that the evidence presented against Smith was admissible because the warrantless search that led to its discovery was justified under an exception to the warrant requirement for actions by law enforcement when lives are in danger.

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