People v. Snider

In People v. Snider, 239 Mich App 393, 608 N.W.2d 502; 397-398; 608 NW2d 502 (2000), a shooting victim identified the defendant as the man who shot him and indicated that the defendant lived in a hotel. A witness also stated that he saw a white van pull into the parking lot and saw a man who matched the defendant's description running away from the van after the victim was hollering that he had been shot. Id. at 397. The police saw a white van with the doors open, the engine running, and the body of a woman who had died from a gunshot wound inside. Id. at 398. The police then obtained a key for the defendant's hotel room and conducted a search of the room without a warrant. Id. The Court found that there were sufficient facts to show exigent circumstances justifying the search. Id. at 407. The Court stated that the police could not wait for a warrant because evidence may have been destroyed and it was necessary to protect the police and others, to prevent the defendant's escape, and to determine if the defendant was wounded. Id. at 410.