State v. Jangala

The state appeals from an order granting defendant’s motion to suppress evidence seized during a warrant-less search at a beer party. The state argues that the warrantless search was supported by probable cause and exigent circumstances. We agree and reverse.

Although we are bound by the trial court’s finding of historical facts when they are supported by the record, we review independently the court’s legal conclusions that are based on those facts. See State v. Stevens, 311 Or 119, 126, 806 P2d 92 (1991). In its memorandum opinion, the court set forth the following facts. On September 27,…