Court of Criminal Appeals of Texas
Laurin Stuart Laney, Appellant v. the State of Texas
October 8, 20032003 Tex. Crim. App. LEXIS 533
Summary
The Court affirmed the appellate judgment, holding that the warrantless entry and search of the appellant's mobile home was justified under the emergency doctrine, a narrow subset of the community caretaking function, because the officers had an objectively reasonable belief that a child’s safety was at risk. The Court clarified that the community caretaking exception does not generally apply to private residences, and emphasized the need for an objective reasonableness standard. Concurring judges noted that the decision should be limited to the Fourth Amendment and expressed concerns about the scope of the doctrine.