Westlake v. Roberts

Citations

• 197 N.E.3d 1040
• 2022 Ohio 3675

Syllabus

Motion to suppress Fourth Amendment warrantless entry home burden exigent circumstances exigencies misdemeanor misdemeanant suspect operating a vehicle while intoxicated intoxicated driver flight pursuit totality of the circumstances particular facts. Reversed the trial court's decision denying a motion to suppress evidence and remanded the case to the trial court with instructions. The warrantless home entry by police in pursuit of a suspected misdemeanant violated the Fourth Amendment. The record showed that the police initiated a traffic stop after a motorist report of a possible intoxicated driver and the suspect pulled into a nearby driveway and fled into his home. Under the particular facts of the case, the city did not demonstrate an exigency that created a compelling law enforcement need for officers to make a warrantless home entry while in pursuit of a misdemeanant suspect.