People v. Aarness

I. Introduction

In this appeal, we review and reverse People v. Aarness, 116 P.3d 1283 (Colo.App.2005), in which the court of appeals held that the trial court erroneously denied defendant Joshua M. Aarness's motion to suppress evidence. While we agree with the court of appeals' application of the two-pronged standard articulated in Payton v. New York, 445 U.S. 573, 100 S.Ct. 1371, 68 L.Ed.2d 639 (1980), which determines when police may enter a home seeking to arrest the subject of an arrest warrant, we hold that the existence of exigent circumstances constitutes an independent basis…