{¶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

{¶29} Another is 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. "[Warrants are generally required to search a person's home or his person unless 'the exigencies of the situation' make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment."

) State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 17, citing United States v. Sharpe, 470 U.S. 675, 682, 105 S.Ct. 1568, 84 L.Ed.2d 605 (1985).

This Court has previously observed as follows regarding the exigent-circumstances exception to the warrant requirement: "One such exception to the Fourth Amendment's warrant requirement is the community-caretaking exception, which courts sometimes refer to as the 'emergency-aid exception' or 'exigent-circumstance exception.'" See State v.Markins, 4th Dist. Scioto No. 10CA3387, 2013-Ohio-602, ¶ 20, quoting State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 15. {¶19} In Markins, we explained that under the exigent-circumstances exception," 'law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.'"

Under the community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement, Officer Kitchen had objective reasonable grounds to believe there was an immediate need for her assistance. See State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 26. {¶22} Therefore, her actions did not violate the Fourth Amendment.

) State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 17, citing United States v. Sharpe, 470 U.S. 675, 682, 105 S.Ct. 1568, 84 L.Ed.2d 605 (1985); see also Illinois v. Rodriguez, 497 U.S. 177, 110 S.Ct. 2793, 111 L.Ed.2d 148 (1990) (saying that the Fourth Amendment does not proscribe all police searches but only those that are unreasonable). "An action is 'reasonable' under the Fourth Amendment, regardless of the individual officer's state of mind, 'as long as the circumstances, viewed objectively, justify [the] action.' "

{¶21} The United States Supreme Court and the Supreme Court of Ohio have recognized a narrower subset of exigent circumstances where law enforcement officers need to respond to emergency situations to protect people from death or serious injury. Brigham City at 403; State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 21. The "emergency-aid" exception allows police to enter a home without a warrant and without probable cause when they reasonably believe, based on specific and articulable facts, that a person within the home is in need of immediate aid.

{¶ 21} The United States Supreme Court and the Supreme Court of Ohio have recognized a narrower subset of exigent circumstances where law enforcement officers need to respond to emergency situations to protect people from death or serious injury. Brigham City at 403, 126 S.Ct. 1943 ; State v. Dunn , 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 21. The "emergency-aid" exception allows police to enter a home without a warrant and without probable cause when they reasonably believe, based on specific and articulable facts, that a person within the home is in need of immediate aid.

" '[C]ourts recognize that a community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement is necessary to allow police to respond to emergency situations where life or limb is in jeopardy.' " Id., quoting State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, ¶ 21. "The bounds of an officer's ability to investigate, pursuant to the community caretaking function, are not limitless."

Instead, O'Malley points to Standard 23-1.1 of the American Bar Association ("ABA") Criminal Justice Standards on Treatment of Prisoners. Courts have relied on the persuasive authority of the ABA's Criminal Justice Standards in countless federal and state opinions. E.g., Strickland v. Washington, 466 U.S. 668, 689 (1984) (referencing ABA Criminal Justice Standards when describing norms of criminal defense representation and stating that "[prevailing norms of practice as reflected in American Bar Association standards and the like . . . are guides to determining what is reasonable, but they are only guides"); State v. Dunn, 964 N.E.2d 1037 (Ohio 2012) (citing 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" in analysis of community-caretakinglemergency-aid exception to warrant requirement of the Fourth Amendment). However, as influential as the ABA's Criminal Justice Standards have been to courts, they are only persuasive authority.