Hill v. Walsh, No. 17-1669 (1st Cir. 2018)Annotate this Case
Here, the First Circuit clarified its circuit’s emergency aid doctrine, holding that police officers seeking to justify their warrantless entry into homes need only demonstrate an objectively reasonable basis for believing that a person within the house is in need of immediate aid. See Michigan v. Fisher, 558 U.S. 45, 47 (2009). The court thus modified its previous pronouncements in United States v. Martins, 413 F.3d 139 (1st Cir. 2005), and its progeny, clarifying that police officers need not establish that their belief approximated probable cause that such an emergency existed.
In this case, the district court entered judgment for Defendants, police officers and the City of Taunton, concluding that the officers did not commit a Fourth Amendment violation because their conduct fell within the emergency aid exception to the warrant requirement. The First Circuit took the opportunity in this case to clarify its emergency aid doctrine to bring its case law in line with Supreme Court precedent. The court then affirmed on the basis that the officers were entitled to qualified immunity and no claim was stated against the City.