The following excerpt is from People v. Amos, 9 N.Y.S.3d 594 (Table) (N.Y. Just. Ct. 2015):
(i) Exigent Circumstances. The People allege that the exigent circumstances presented in the instant case result from the fact that the police believed that the defendant was having a medical emergency due to diabetes. Medical emergencies have been recognized as a basis for the warrantless entry of a residence. However, the police must have an objective basis for believing that such a medical emergency exists. (Brigham City, Utah v. Stuart, 547 U.S. 398, 126 S.Ct. 1943, 164 L. ED.2d 650 [2006] ) This would be the case even if the officer's actual or additional motive was to investigate a crime. The United States Supreme court has determined that the subjective motivation of the officer is irrelevant. (See Wren v. United States, 517 U.S. 806 [1996].).
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