Washington v. Teulilo (Majority and Dissent)

Interlocutory review was granted to challenge a trial court’s denial of a suppression motion of evidence observed during a warrantless entry into a dwelling. The trial court concluded that the entry was justified, applying what cases characterized as the “community caretaking exception” to the warrant requirement, based on rendering emergency aid and conducting a health and safety check. At issue before the Washington Supreme Court whether the United States Supreme Court’s Fourth Amendment case, Caniglia v. Strom, 141 S. Ct. 1596 (2021), required the Washington Court to reevaluate the state constitution article I, section 7 cases recognizing exceptions to the warrant requirement. Petitioner Ului Lakepa Teulilo argued that the United States Supreme Court invalidated the community caretaking exception to the warrant requirement as applied to the home, and therefore, under the supremacy clause, Washington state cases recognizing a health and safety check exception under the same doctrine were invalid. To this, the Washington Supreme Court disagreed, and affirmed the trial court.