Wednesday, March 11, 2026
Page 3
Court of Appeal:
Warrantless Search Following 15-Hour Standoff Was Valid
By a MetNews Staff Writer
Exigent circumstances justified the warrantless entry by members of the Los Angeles Sheriff’s Department SWAT team into an apartment—after a 15-hour standoff—to apprehend a man who, earlier, fatally shot a Pomona police officer who was holding a ballistics shield while others used a battering ram, Div. Eight of this district’s Court of Appeal declared yesterday.
The appellant, Isaias Dejesus Valencia, was convicted of the murder of Pomona Police Officer Greggory Casillas and other felonies. Valencia had been driving erratically, attracting the attention of police, was pursued, crashed into a parked car, and ran to his apartment where he barricaded himself.
“A SWAT team eventually blew through his bedroom wall and blasted down his bedroom door,” Justice John Shepard Wiley Jr. recounted in the opinion.
“Police had ample justification for their hot pursuit of a felon,” he wrote, adding that “their hot pursuit justified their warrantless entry.”
Wiley recited that the confrontation began at about 9 p.m. and ended past noon the following day.
Objective Reasonableness
He said:
“The Fourth Amendment to the Constitution protects Americans against unreasonable police searches and seizures in their homes. The touchstone is reasonableness, which generally requires a judicial warrant before police can enter a home without permission. An exception is for exigent circumstances, which arise when the situation makes the needs of law enforcement so compelling that a warrantless search is objectively reasonable. This exception enables police to handle emergencies: situations presenting a compelling need for official action that leave no time to secure a warrant.”
Wiley continued:
“Whether a now-or-never situation actually exists—in other words, whether an officer has no time to secure a warrant—depends upon facts on the ground. Courts thus look at the totality of circumstances confronting officers as they decide to make warrantless entries.”
The jurist noted that Valencia had been driving in such a manner as to suggest that he was under the influence of drugs—and tests showed he had methamphetamine and cocaine in his blood stream—and that evidence of drug use dissipates with the passage of time.
Pressing Need
He explained:
“[T]he circumstances were exigent because the blood evidence was dissipating, as it always is, and a pressing safety need took priority over a warrant application.…Valencia’s conduct had been irrational, unpredictable, confrontational, and hazardous to the public and himself. He had posed a flagrant risk to others, to himself, and to the property of others. Once in his second-floor apartment, would he try to escape via a fire exit, a balcony, or a window? Would he try ropes, sheets, a hanging drop, or a wild leap onto some intermediate surface? Would he harm himself? Would he take hostages? Would he hurt people in the apartment? Would he procure or fashion weapons? Would he light fires? How rapidly would the situation evolve? For every possibility, the answer for the pursuing police was: who knows?
“No limits were apparent.”
Wiley added:
“Once inside, police were not required to interrupt their efforts to seek a warrant. Officers on the scene must be able to devote their full attention to the threat they face. The Fourth Amendment did not require them periodically to reassess whether the exigency persisted throughout the standoff….Exigencies can persist while police pursue time-consuming courses of action.”
The matter was remanded for sentencing errors to be corrected.
The case is People v. Valencia, B338672.
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