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."

{¶ 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[.

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. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, syllabus. In Dunn, the Ohio Supreme Court cited ABA Standards for Criminal Justice § 1–2.2 for the proposition that "police officers are duty-bound to provide emergency services to those who are in danger of physical harm."

“ ‘The need to protect or preserve life or avoid serious injury is justification for what would be otherwise illegal absent an exigency or emergency.’ ” [State v.] Dunn [, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037], ¶ 18, quoting Wayne v. United States, 318 F.2d 205, 212, 115 U.S.App.D.C. 234 (D.C.Cir.1963) (the community-caretaking/emergency-aid exception allows a law-enforcement officer to act without a warrant when the officer has objectively reasonable grounds to believe that there is an immediate need for the officer's assistance to protect life or prevent serious injury); [State v. ]Hyde [, 26 Ohio App.2d 32, 33, 268 N.E.2d 820 (9th Dist.1971) (the emergency-aid exception to the warrant requirement is satisfied by a showing the police officers had reasonable grounds to believe that some kind of emergency existed). “The ultimate standard set forth in the Fourth Amendment is reasonableness.”

{¶14} Warrantless searches are presumptively unconstitutional, but several exceptions to the warrant requirement have been delineated by the courts, including the one pertinent to this case, the "community-caretaking exception," which courts sometimes refer to as the "emergency-aid exception" or "exigent-circumstance exception." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 15. The exception is based on a recognition that

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. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, syllabus. Test as Applied to this Case

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.

{¶19} Under the community-caretaking/emergency aid exception to the Fourth Amendment, police officers may "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, syllabus. The exception recognizes that "local law-enforcement officers 'frequently investigate vehicle accidents in which there is no claim of criminal liability and engage in what, for want of a better term, may be described as community caretaking functions, totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.'"

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