State v. Carlson

HARRIS, Justice.

On the basis of a missing person report, officers seized evidence during a nighttime warrantless search of defendant’s residence following a forced entry. The question, whether the search was valid, turns on whether a “health and safety” search is authorized under certain extreme circumstances. We think it is authorized, and believe the facts here present the perfect model for its correct application. We accordingly affirm defendant’s murder conviction.

In the early morning hours of January 27, 1994, police received a missing person report from Rhonda Young. She was concerned…