People v. Stolz CA2/6

DISCUSSION

Stolz contends the judgment should be reversed because Sergeant Chesson’s search of the safe in his garage and seizure of its contents violated the Fourth Amendment. We agree. “In California, issues relating to the suppression of evidence . . . are reviewed under federal constitutional standards.” (People v. Troyer (2011) 51 Cal.4th 599, 606 (Troyer).) Under the Fourth Amendment, “a warrantless entry into a home is presumptively unreasonable.” (Troyer, at p. 606.) Prosecutors thus had “the burden of establishing that . . . [an] exception to the warrant requirement justified the entry” into Stolz’s home. (Ibid.) In reviewing the trial court’s determination that prosecutors met that burden, we defer to the court’s factual findings if supported by substantial evidence. (People v. Tully (2012) 54 Cal.4th 952, 979.) We then exercise our independent judgment to determine whether the court’s ruling on the suppression motion was correct. (Ibid.) Emergency aid exception The trial court erred when it denied Stolz’s motion to suppress the evidence found in his safe. As to the first basis prosecutors put forth to justify Sergeant Chesson’s search—the “emergency aid exception”—the…