The community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement allows a law-enforcement officer with objectively reasonable grounds to believe that there is an immediate need for his or her assistance to protect life or prevent serious injury to effect a community-caretaking/emergency-aid stop. 131 Ohio St.3d 325, 2012-Ohio-1008, ¶ 26, 964 N.E.2d 1037. In concluding that the community caretaking exception did not supply a valid basis for Trooper Byers's stop of Moiduddin's vehicle, the trial court found that the "totality of the circumstances * * * d[id] not suggest that there was an immediate need for assistance to protect life or prevent serious injury."
The court has also characterized situations befitting the emergency-aid exception as placing "life or limb * * * in jeopardy." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 21. We therefore understand the emergency-aid exception to excuse the warrant requirement in circumstances where the time it takes to obtain a warrant may place a person's life in danger.
State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, syllabus.
Brigham City v. Stuart, 547 U.S. at 403, 405-406, 126 S.Ct. 1943, 164 L.Ed.2d 650 (2006), quoting Mincey v. Arizona, 437 U.S. 385, 392, 98 S.Ct. 2408, 57 L.Ed.2d 209 (1978). Accord, State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, syllabus. {¶33} In Ohio, the Supreme Court has held,
{¶ 8} At the suppression hearing, the State argued that the warrantless entry of Mr. Linder's house fell within the exigent circumstances exception, other times known as the community-caretaking exception. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 15. In Dunn, the Ohio Supreme Court explained that the exception exists because "police officers are duty-bound to provide emergency services to those who are in danger of physical harm[.
Another exception is the community-caretaking/emergency-aid exception which "allows police officers to stop a person to render aid if they reasonably believe that there is an immediate need for their assistance to protect life or prevent serious injury." State v. Dunn, 131 Ohio St. 3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 22.
State courts have permitted police officers to justify vehicular stops based on the emergency-aid exception. See State v. Dunn , 131 Ohio St.3d 325, 964 N.E.2d 1037, 1042 (2012) ; State v. Stapa , 46 So.3d 264, 266 (La. App. 2 Cir. 2010).See, e.g. , United States v. Collins , 321 F.3d 691, 694–95 (8th Cir. 2003) (permitting officer to lean into parked car because he had reasonable belief that persons were injured); United States v. Kelly , 267 F.Supp.2d 5, 9 (D.D.C. 2003) (no Fourth Amendment violation where officers entered car to treat visible crash victim).
Therefore, " Miranda does not apply." State v. Dunn , 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24.2. Statements between Summit County Jail and Warren Police Station
State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24. In the case at bar, we conclude that appellant had not been placed in custody when he made these statements.
The emergency-aid exception allows law enforcement officers to make a warrantless entry into a home or curtilage to render aid if they reasonably believe there is the immediate need for assistance to protect life or prevent serious injury. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 20-22. The emergency aid exception applies where there is an objectively reasonable basis for believing that the subject is in need of immediate aid.