Statev.Wood
After Amber Carter called 911 about Garrett Wood’s suspected overdose, police entered their hotel room to aid him. Once paramedics took Wood away, an officer reentered and questioned Carter; officers then opened containers and bags, found suspected methamphetamine and equipment, and arrested Carter. Drug-task-force agents later obtained a warrant, and Wood and Carter were charged with trafficking and other drug offenses. The trial court suppressed the evidence. The Court of Appeals affirmed. The initial emergency-aid entry was lawful, but that justification ended when paramedics assumed care and removed Wood; officers had no consent or other exigency for the later reentry and searches. The State could not rely on danger from suspected meth-lab items discovered during the unlawful search, particularly where no active lab existed. The later warrant did not establish inevitable discovery because the State showed no officers were actively pursuing a warrant before the unlawful searches began. The court also declined to decide whether Georgia’s drug-overdose immunity law covered the charged offenses because the trial court had made no immunity ruling for review.
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