Hull

The defendant, John David Hull, stole stereo speakers from a vehicle. The vehicle, however, had been placed on the street as bait by the Roseville Police Department, and the speakers contained a tracking device and were covered with powder visible in ultraviolet light. Within minutes of the burglary, the officer followed the tracking device signal to a residence, entered the residence without a warrant, and arrested the defendant, who was inside the residence. The defendant’s motion to suppress the evidence obtained when the officer entered the residence was denied, and, after pleading guilty, the defendant appeals.

We hold that whether exigent circumstances justified a warrantless entry into the residence is determined by viewing the circumstances objectively. Turning to the facts of this case, we conclude the entry was justified by exigent circumstances because of the ephemeral nature of the evidence within the residence. Accordingly, we affirm.

Facts

On June 30, 1992, at 12:25 a.m., Roseville Police Officer William Herring responded to a “signal 1000,” an alarm activation in one of the City of Roseville’s bait vehicles. He discovered the driver’s side window of the…