In State v. Fisher, 141 Ariz. 227, 237-41, 686 P.2d 750, 760-64 (1984), the Arizona Supreme Court cited to Mincey v. Arizona, 437 U.S. 385, 392-94, 98 S. Ct. 2408, 57 L. Ed. 2d 290 (1978) and other courts in applying the emergency aid doctrine. 141 Ariz. at 237, 686 P.2d at 760. Citing: Mincey v. Arizona, 437 U.S. 385, 98 S. Ct. 2408, 57 L. Ed. 2d 290 (1978); State v. Wright, 125 Ariz. 36, 607 P.2d 19 (App. 1979); People v. Reynolds, 672 P.2d 529 (Colo. 1983); United States v. Booth, 455 A.2d 1351 (D.C. App. 1983); People v. Mitchell, 39 N.Y.2d 173, 347 N.E.2d 607, 383 N.Y.S.2d 246, cert. denied, 426 U.S. 953, 96 S. Ct. 3178, 49 L. Ed. 2d 1191 (1976); State v. Jones, 45 Or. App. 617, 608 P.2d 1220 (1980)). The facts in Fisher involved the warrantless search of defendant's apartment. 141 Ariz. at 235, 686 P.2d at 758. A friend of the defendant became concerned about the welfare of the defendant after a murder had occurred. Id. In responding to the welfare check of the defendant's apartment, the police found evidence that the defendant was involved in the murder. Id. at 235-36, 686 P.2d at 758-59. The defendant moved to suppress it. Id. at 236, 686 P.2d at 759. the trial court denied the motion, and the Arizona Supreme Court affirmed. Id. Fisher recognized that "because it is not unreasonable for police to enter a dwelling for the purposes of providing emergency aid or assistance, such entries are not proscribed by the fourth amendment." Id. at 237, 686 P.2d at 760. The exception "provides that officers of the state may enter a dwelling without the benefit of a warrant where they reasonably believe there is someone within in need of immediate aid or assistance." Id. The court established three elements to determine whether the emergency aid exception applies: (1) the police must have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property. (2) the search must not be primarily motivated by intent to arrest and seize evidence. (3) There must be some reasonable basis, approximating probable cause, to associate the emergency with the area or place to be searched. Id. at 237-38, 686 P.2d at 760-61. (quoting People v. Mitchell, 39 N.Y.2d 173, 347 N.E.2d 607, 609, 383 N.Y.S.2d 246 (N.Y. 1976)); See also State v. Jones, 188 Ariz. 388, 395-96, 937 P.2d 310, 317-18 (1997) (applying the three elements of the emergency aid exception).