Gallmeyer v. State
In Gallmeyer v. State, 640 P.2d 837 (Alaska App. 1982), the Court ruled that the police have the authority to enter premises without a warrant when they have probable cause to believe that they must enter to render aid or prevent further injury in an emergency that threatens life or property.
The Gallmeyer decision sets forth three elements that the government must prove in order to justify a warrantless entry under the emergency aid doctrine:
(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[, and]
(3) There must be some reasonable basis, approximating probable cause, to associate the emergency with the area or place to be searched. Id. at 842.