State v. EvansAnnotate this Case
The Supreme Court affirmed the judgment of the district court concluding that the State had not met its burden of establishing the application of an established exception to the warrant requirement in justifying the constitutionality of the warrantless search of Defendant’s purse and wallet, holding that the search was not permitted under any of the exceptions to the warrant requirement.
This case arose from the action of law enforcement officers conducting a warrantless search of Defendant’s purse and wallet after an ambulance took her from the scene of an accident. The State argued that the plain-view exception and the officer’s administrative caretaking function of locating a driver’s license to complete an accident report justified the warrantless search. The trial judge granted Defendant’s motion to suppress, concluding that the search violated Defendant’s constitutional rights. The Supreme Court affirmed, holding that the warrantless search was not permitted under any exception to the warrant requirement, and therefore, the evidence seized during the search must be suppressed.