State v. Tran
State v. Tran, 2024 UT 7 (Pohlman, J.)
Criminal / Constitutional Law
After Grandmother failed to pick up Grandson from school, police officers responded to a welfare check at her last known address. When no one responded to their knocks on the front door, officers entered through an open door. They found the bodies of Grandmother, Infant, and a male, and saw Tran holding a gun. After the State charged Tran with three counts of aggravated murder, Tran moved to suppress the evidence obtained as a result of the warrantless entry. The district court denied his motion, and Tran filed an interlocutory appeal, arguing that the warrantless entry and search of his home violated both the Fourth Amendment of the U.S. Constitution and Article I, section 14 of the Utah Constitution. The Utah Supreme Court affirmed, holding:
- The totality of the circumstances supported an objectively reasonable basis for the police officers to believe that Grandmother and Infant were in need of immediate aid and forgo obtaining a warrant.
- Tran’s state constitutional claim fails on the same ground as his Fourth Amendment claim.
- Practice tip: Under the emergency aid exception, the reasonableness of an objectively reasonable belief considers the objective circumstances facing a reasonable officer—not the actual officers’ response to those circumstances.
- Practice tip: The Court encourages parties to press state constitutional claims further so that it may engage in a principled exploration of the interplay between federal and state protections of individual rights.
- Judicial tip: The Court found it unnecessary to take a fixed position on whether it should address federal or state constitutional claims in a particular order in the search and seizure context; instead, the Court would rather take a case-by-case approach to determine whether there are any advantages or disadvantages in addressing one constitutional claim before the other.