United States v. Rowell, 2026 WL 457337 (1st Cir. 2026)
The Fourth Amendment generally requires a warrant before entering a home. That rule is old and solid. But like most rules in police work, it has narrow exceptions. One of them is the emergency-aid exception. In United States v. Rowell, the court examined whether officers lawfully entered an apartment without a warrant while searching for a missing minor. This case is a clear reminder of what the emergency-aid exception requires — and what it does not.
In Belmont, Massachusetts, a father reported his minor child missing. He believed the child was endangered. Investigators traced the minor’s Snapchat activity to an IP address associated with a specific apartment building. Officers went to the building. After one tenant denied entry to the officers, another tenant allowed them into the common area. The officers approached the unit associated with the IP address. The apartment door was unlocked.
The officers asked the occupants for permission to search for the missing minor, and the occupants denied consent to enter. Just then, Keion Rowell emerged from a bedroom holding a cell phone. The officers entered briefly — not to search drawers or sweep rooms — but to ask about the missing child. Luckily, the missing minor was located. Evidence later used in prosecution flowed from that contact.
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Rowell moved to suppress, arguing the warrantless entry violated the Fourth Amendment. The U.S. Supreme Court recently reaffirmed the emergency-aid exception in Case v. Montana (2026 WL 96690 (U.S. 2026)). The emergency-aid exception allows officers to enter a home without a warrant when they have an objectively reasonable basis to believe someone inside is in need of immediate aid. The emergency-aid doctrine is not about crime control. It is not about evidence gathering. It is about protecting life or preventing serious injury.
Courts ask a practical question: Would a reasonable officer, given the facts known at the time, believe someone inside needed immediate assistance? This is an objective test. The officer’s subjective motivation does not control. The 1st Circuit focused on what officers knew before they crossed the threshold. First, a child was missing. The parent believed she was endangered. Digital tracing placed the child’s recent online activity at that specific apartment. Time was passing.
The emergency-aid doctrine is not about crime control. It is not about evidence gathering. It is about protecting life or preventing serious injury.
A missing minor, potentially being trafficked or harmed, creates a different urgency than a routine investigation. The court emphasized the officers were not acting on a vague tip. They had specific, contemporaneous information linking the missing child to that location. When they entered, their purpose was narrow: locate and check on the welfare of the child. Under those circumstances, the court held the warrantless entry fit squarely within the emergency-aid doctrine.
Here are some takeaways for officers:
- The emergency must be concrete, not speculative. “Someone might be in danger” is not enough. In this case, officers had a missing child, a concerned parent, and digital evidence placing the child at a specific location. That combination created an objectively reasonable belief of potential danger. Missing minors change the urgency analysis. Courts consistently recognize that endangered children present heightened concerns. When officers can articulate specific facts showing a minor may be at risk inside a particular location, emergency-aid justification becomes far stronger.
- The scope of the intrusion must match the emergency. The emergency-aid entry is not a wide-open search warrant exception. Entry is allowed to address the emergency, in this case to locate the child, ensure her safety, and neutralize immediate danger. The narrower and more focused your actions, the stronger your legal footing.
- Technology can supply exigency. Digital location data — IP tracing, app activity, geolocation — can contribute to the “objectively reasonable belief” analysis. But it must point to something specific and timely. Old or vague digital information will not carry the same weight.
- The Fourth Amendment protects homes. Warrantless entry is the exception, not the rule. But when officers have specific, articulable facts showing a person (especially a minor) may be inside and in danger, the law does not require them to stand outside drafting paperwork while harm unfolds. Rowell reinforces a practical truth: Emergency aid requires facts, urgency, and discipline in scope. When those elements are present, courts will back the decision to enter.
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