What is the standard of review for a suppression ruling?

The standard of review for a suppression ruling "is well established. We defer to the trial court's factual findings, express or implied, where supported by substantial evidence. In determining whether, on the facts so found, the search or seizure was reasonable under the Fourth Amendment, we exercise our independent judgment." (People v. Glaser (1995) 11 Cal.4th 354, 362.)

"The Fourth Amendment to the federal Constitution guarantees against unreasonable searches and seizures by law enforcement and other government officials. Because a warrantless entry into a home to conduct a search and seizure is presumptively unreasonable under the Fourth Amendment [citation], the government bears the burden of establishing that exigent circumstances or another exception to the warrant requirement justified the entry." (People v. Rogers (2009) 46 Cal.4th 1136, 1156, fn. omitted.)

" ' "[Exigent] circumstances" means an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property.' " (People v. Lucero (1988) 44 Cal.3d 1006, 1017.) "The need to render emergency aid is a well-recognized part of the exigent circumstances exception. But it has always required that articulable facts support a reasonable belief that an emergency exists." (People v. Ovieda (2019) 7 Cal.5th 1034, 1048.) Accordingly, officers "may enter a home without a warrant when

Page 5