Id. at ___, 138 S.Ct. at 2223; see also State v. Sessions, 165 Idaho 658, 661, 450 P.3d 306, 309 (2019) (noting emergency aid exception to protect against imminent injury or aid injured individual); State v. Holton, 132 Idaho 501, 504, 975 P.2d 789, 792 (1999) (noting need to protect or preserve life or avoid serious injury is exigent circumstance).
Warrantless searches and seizures within a home are presumptively unreasonable and therefore violate the Fourth Amendment. State v. Sessions, 165 Idaho 658, 660, 450 P.3d 306, 308 (2019). The State may overcome this presumption by demonstrating that a warrantless search either fell within a well-recognized exception to the warrant requirement or was otherwise reasonable under the circumstances.
"[W]arrants are generally required to search a person's home ... 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. Sessions , 165 Idaho 658, 661, 450 P.3d 306, 309 (2019) (quoting Stuart , 547 U.S. at 403, 126 S.Ct. 1943 ). "The [exigent circumstances] exception applies where the facts known at the time of the entry indicate a ‘compelling need for official action and no time to secure a warrant.’ "
Warrantless arrests are presumptively unreasonable. State v. Sessions, 165 Idaho 658, 660, 450 P.3d 306, 308 (2019). However, a warrantless arrest by law enforcement is reasonable and lawful under the Fourth Amendment where there is probable cause to believe that a criminal offense has been or is being committed.
Conversely, exigent circumstances do not exist when there is no obvious sign of distress and there are less intrusive means to determine whether there is an immediate need to enter the home. State v. Sessions, 165 Idaho 658, 661, 450 P.3d 306, 309 (2019); State v. Reynolds, 146 Idaho 466, 471, 197 P.3d 327, 332 (Ct. App. 2008).