GA: 911 call about a possible dead body at a mobile home didn’t need to be corroborated

A call about a possible dead body at a location where police had responded before was sufficiently specific to justify an emergency response. On this record, their belief was objectively reasonable, and the story didn’t need to be corroborated. Tidwell v. State, 2021 Ga. LEXIS 621 (Sept. 21, 2021):

The crux of Tidwell’s argument is that, because the initial 911 caller only notified officers of a “body” inside a mobile home, officers did not have enough information that the person inside was in need of immediate aid. However, “[o]fficers do not need ironclad proof of a likely serious, life-threatening injury to invoke the emergency aid exception.” (Punctuation omitted.) Michigan v. Fisher, 558 U.S. 45, 49 (130 SCt 546, 175 LE2d 410) (2009). The test, as explained by the Supreme Court, “is not what [officers subjectively] believed, but whether there was ‘an objectively reasonable basis for believing’ that medical assistance was needed, or persons were in danger.” Id. (quoting Brigham City, supra, 547 U.S. at 406 and Mincey, supra, 437 U.S. at 392). Here, the record shows that officers received a tip about a possible dead body inside a mobile home; had responded to the residence on prior occasions for verbal disputes; and that, after knocking on the front door and receiving no response, officers noticed that the front door was unsecure and that there were pry marks near the door handle. Based on the foregoing, we agree with the trial court that it was objectively reasonable for the officers to believe that a person inside the mobile home was “seriously injured or imminently threatened with such injury.” Brigham City, supra, 547 U.S. at 400. See also Teal, supra, 282 Ga. at 322-323 (emergency aid exception applied to initial entry into motel room by officers responding to a call reporting a “bound, motionless body” visible through the room’s window). Consequently, the trial court did not err in denying Tidwell’s pretrial motion to suppress.