Cited by

Under the collective-knowledge doctrine, “the officer who conducts the search is imputed with knowledge of all facts known by other officers involved in the investigation, as long as the officers have some degree of communication between them.” (emphasis added).

at 632 ().5 Of particular relevance here, the subjective motivation of the officer is irrelevant to the application of the emergency- aid exception under the Fourth Amendment.

Under the collective- knowledge doctrine, “the officer who conducts the search is imputed with knowledge of all facts known by other officers involved in the investigation, as long as the officers have some degree of communication between them,” though “[a]ctual communication of information to the officer conducting the search is unnecessary.”

IV; Minn. Const. art. 1, § 10; State v. Lemieux

-88 (Minn. 2007); -34 (Minn. 2018).

s when (1) police “‘have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property ’ and [(2)] ‘there [is] some reasonable basis, approximating probable cause, to associate the emergenc y with the area or place to be searched.’” ().1 The exception allows officers to “enter a home without a warrant to render emergency assistance to a n injured occupant or to protect one from imminent injury.”

A search based on exigent circumstances must be “limited to the scope of the emergency.”

5 basis, approximating probable cause, to associate the emergency with the area or place to be searched.” (quotation omitted).

-88 (Minn. 2007); Richards, d at 203.

Emergency aid Police “‘may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.’” -88 (Minn. 2007) (quoting Brigham City v. Stuart, 547 U.S. 398, 403, 126 13 S. Ct. 1943, 1947 (2006)).

‘may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.’” -88 (Minn. 2007) (quoting Brigham City v. Stuart , 547 U.S. 398, 403, 126 S. Ct. 1943, 1947 (2006)).

See State v. Lemieux , , 787-88 (Minn. 2007).

“[T]he officer who conducts th e search is imputed with knowledge of all facts known by the other officers involved in the investigation, as long as the officers have some degree of communication.” 3 The officers here acted in con cert and spoke to one another.

There is a two-part test to determine whether the emergency exception applies: “(1) is the officer motivated by the need to render aid or assistance; and (2) under the circumstances, would a reasonable person believe that an emergency existed.” Id.; (stating that two principles must be kept in mind when applying the emergency exception: the state bears the burden to demonstrate that police conduct was justified and the reasonableness of an officer’s belief that an emergency existed is judged fro

In re Welfare of G. (NMN) M. , aff’d, see State v. Lemieux , (discussin g communication requirement in context of warrantless search).

Under the collective-knowledge doctrine, an officer who makes a warrantless seizure “ is imputed with knowledge of all facts known by other officers involved in the investigation, as long as the officers have some degree of communication between them.” (warrantless search).

Under this approach, “the officer who conducts the search is imputed with knowledge of all facts known by other officers involved in the investigation, as long as the off icers have some degree of communication between them.”

-90 (Minn. 2007) (holding warrantless entry of residence was justified by need to search for 11 intruders or injured occupants); see also Lopez, d at 23 (concluding warrantless seizure of unconscious driver was justified by emergency-aid exception).

The emergency-aid exception is one exception to the warrant requirement that allows law enforcement officers, in pursuing “a community- caretaking function,” to “‘enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.’” -88 (Minn. 2007) (quoting Brigham City v. Stuart, 547 U.S. 398, 403, 126 S. Ct. 1943, 1947 (2006)).

Under the emergency-aid exception, police officers, “in pursuing a community-caretaking function, may enter a home without a warrant to render emergency assistance to an injured occupant or to protect 4 an occupant from imminent injury.” –88 (Minn. 2007) (quotation omitted).

“When this court reviews a trial court’s order following an omnibus hearing, determinations of reasonable suspicion and probable cause as they relate to searches and seizures ‘should be reviewed de novo on appeal.’” (-83 (Minn. 1998)) “The question of the legality of the arrest turns not on the reasonableness or practicality of obtaining a warrant, but on the reasonableness of the arrest.”

When reviewing pretrial orders on motions to suppress evidence, we review the district court’s factual findings for clear error, 4 (Minn. 2007), and its decision whether to suppress the evidence as a matter of law

4 Emergency-Aid Exception Under the emergency-aid exception, a police officer may “enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.” -88 (Minn. 2007).

Richards, d at 203; Hummel, d at 72; - 88 (Minn. 2007).

Thus, “determinations of reasonable suspicion and probable cause as they relate to searches and seizures should be reviewed de novo on appeal.” (quotation omitted).

Under the emergency-aid exception to the warrant requirement, police officers, “in pursuing a community-caretaking function, may enter a house without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent 6 injury.” -88 (Minn. 2007) (quotation omitted).

DECISION When reviewing pretrial orders on motions to suppress evidence, we review the district court’s factual findings for clear error, and its decision whether to suppress the evidence as a matter of law

Actual communication of information to the officer conducting the search is unnecessary.” (citations omitted).