State v. Gibson
In State v. Gibson, 267 P.3d 645, 650 (Alaska 2012) the Alaska Supreme Court held that the Alaska constitutional standard for the emergency aid doctrine affords greater protection against warrantless searches and seizures than the United States Constitution.
Under this standard, the State must meet the three-pronged Gallmeyer test (Gallmeyer v. State) to justify a warrantless search under the emergency aid exception:
(1) the police must have reasonable grounds to believe there is an emergency at hand and an immediate need for their assistance in the protection of life or property; (2) the search must not be primarily motivated by the intent to arrest a person or to 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. (citing Gallmeyer v. State, 640 P.2d 837, 842 (Alaska App. 1982)).
The Court held that a police entry into a residence can be justified under the emergency aid doctrine, if the police have a reasonable belief that there might be someone injured in the premises.