Commonwealth v. Kaeppeler
Annotate this CaseAfter learning that two of the guests from a party at Defendant’s house were ill from ingesting tequila and that Defendant might also be ill, the police entered Defendant’s home to perform a well-being check under the “emergency aid” exception to the constitutional warrant requirement. While there, the police seized two tequila bottles, one of which was found to contain a so-called “date rape” drug. Defendant filed a motion to suppress, which the trial court denied. After a jury trial, Defendant was convicted of rape, drugging for sexual intercourse, and drugging to confine. The Supreme Judicial Court vacated the judgments of conviction, holding (1) the police had objectively reasonable grounds to believe that Defendant may be in need of immediate medical assistance, and therefore, the warrantless entry into Defendant’s home was justified; but (2) the seizure of the evidence was unreasonable because (i) it occurred after Defendant was transported to the hospital and while the police remained in his home without his consent, and (ii) the police seized the evidence for investigative purposes without verifying any demonstrable relationship to the emergency justifying their entry into Defendant’s home. Remanded for a new trial.
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