State of South Dakota, Plaintiff and Appellee v. Brian Lee Deneui, Defendant and Appellant

Summary

The court held that officers lawfully entered the defendant's home without a warrant under the community-caretaker exception because objective circumstances, including toxic ammonia fumes, an unsecured residence, and uncertainty about whether anyone remained inside, reasonably justified a limited welfare check. The court also upheld the search warrant and the convictions for manufacturing, possession, and maintaining a place where controlled substances were used or stored. It reversed one of the two overlapping drug-free-school-zone convictions as violating double jeopardy and remanded to strike that conviction and its sentence. Justice Meierhenry, dissenting, would have refused to extend the community-caretaker exception to homes.