State v. Geisler
In State v. Geisler, 222 Conn. 672, 693, 610 A.2d 1225 (1992), the Court set forth the standard of review for determining whether the emergency doctrine justifies a warrantless search. We review the "applicability of the emergency doctrine . . . de novo . . . based upon the subordinate facts found by the trial court, to determine whether an emergency existed that would justify the warrantless entry into the dwelling.
"Facts found by the trial court will not be disturbed unless the finding is clearly erroneous. . . . Conclusions drawn from those underlying facts must be legal and logical. . . . An appellate court reviews conclusions based upon subordinate facts found, even if labeled conclusions of fact, to the same extent that it reviews conclusions of law. . . . Because the issue of the warrantless entry into a person's home involves his or her constitutional rights, a reviewing court must examine the record thoroughly to determine whether the subordinate facts justify the trial court's conclusion that the officers' belief that an emergency existed was reasonable." Id.