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State v. Luckey

2026-08-26

Summary

Holding. The court affirmed the trial court's judgment, holding that Officer Drach's warrantless entry into Luckey's apartment was justified under the exigent circumstances exception to the Fourth Amendment because a reasonable police officer would have believed the autistic, nonverbal child left alone for over 13 hours faced an immediate threat to health or safety.

Veasia Luckey was charged with endangering a child under Ohio law after police discovered her apartment empty of appropriate supervision and living conditions. Luckey challenged the search on Fourth Amendment grounds, arguing that the officer's warrantless entry violated her constitutional protections. The trial court denied her motion to suppress, and she appealed after entering a no-contest plea and conviction.

The appellate court agreed with the state that exigent circumstances justified the warrantless search. Officer Kelly Drach had been called to the apartment after learning from the building manager that a young, nonverbal, autistic child had been alone for approximately 13 hours with no access to food or bathroom facilities. Upon entry, the officer observed hazardous conditions throughout the dwelling. Under these facts, the court found that a reasonable police officer would have believed an emergency existed requiring immediate action to protect the child's welfare, making a warrant impractical and potentially dangerous.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether warrantless search of home violated Fourth Amendment rights
  • Whether exigent circumstances justified emergency entry without warrant
  • Whether officer reasonably believed child faced immediate danger

Procedural posture

The defendant appealed from the trial court's denial of her motion to suppress evidence obtained during a warrantless search of her apartment in a child endangering case.

Authorities cited

Opinion

majority opinion

[Cite as State v. Luckey, 2026-Ohio-3327.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250684

TRIAL NO. 25/CRB/8723

Plaintiff-Appellee, :

vs. :

JUDGMENT ENTRY

VEASIA LUCKEY, :

Defendant-Appellant. :

This cause was heard upon the appeal, the record, and the briefs.

For the reasons set forth in the Opinion filed this date, the judgment of the trial court is affirmed.

Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs be taxed under App.R. 24.

The court further orders that (1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and (2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk:

Enter upon the journal of the court on 8/26/2026.

Pursuant to App.R. 30, the clerk is directed to send all parties, or their counsel if represented, a copy of the court’s judgment and note such action on the docket.

By:_______________________

Administrative Judge

[Cite as State v. Luckey, 2026-Ohio-3327.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250684

TRIAL NO. 25/CRB/8723

Plaintiff-Appellee, :

vs. :

OPINION

VEASIA LUCKEY, :

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Municipal Court

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: August 26, 2026

Emily Smart Woerner, City Solicitor, Susan M. Zurface, Chief Prosecuting Attorney, and Carla N. Weaver and Robert E. Rickey, Assistant Prosecuting Attorneys, for Plaintiff-Appellee,

Angela W. Chang, Hamilton County Public Defender, and Joshua A. Thompson, Assistant Public Defender, for Defendant-Appellant.

[Cite as State v. Luckey, 2026-Ohio-3327.]

NESTOR, Judge.

{¶1} After receiving a report that a young child had been left home alone,

Cincinnati police entered defendant-appellant Veasia Luckey’s home without a

warrant. Luckey argues that this warrantless search violated her constitutional rights.

The State contends that the search was justified in order to ensure the safety and

wellbeing of the child.

{¶2} We agree with the State. The police officer in this case was privileged to

enter the home without a warrant based on exigent circumstances.

I. Factual and Procedural History

{¶3} Luckey was charged with endangering children under R.C. 2919.22(A),

which is a first-degree misdemeanor. She filed a motion to suppress, arguing that a

warrantless search of her apartment violated her Fourth Amendment rights. The

following facts were discerned at the suppression hearing.

{¶4} On May 27, 2025, Officer Kelly Drach was dispatched to an apartment

building in Walnut Hills. When Officer Drach arrived, she spoke with the building

manager, who informed her that a child had been left alone in an apartment for

approximately 13 hours. When describing the child, the building manager stated that

the child was “just a baby.” The building manager also told Officer Drach that the child

was nonverbal and on the autism spectrum. This interaction was captured on Officer

Drach’s body-worn camera footage (“BWC”), which was viewed by the trial court and

admitted into evidence at the hearing.

{¶5} Based on this information, Officer Drach decided to enter the

apartment. Officer Drach testified that when she entered the apartment, she saw

“filth” and “trash all over the floor.” She also testified that the child did not have access

to food or a restroom.

OHIO FIRST DISTRICT COURT OF APPEALS

{¶6} The trial court denied Luckey’s motion to suppress, reasoning that the

exigent circumstances provided Officer Drach with a reasonable basis to enter the

apartment.

{¶7} Luckey pleaded no-contest and was subsequently found guilty of child

endangering. She now appeals.

II. Analysis

{¶8} In one assignment of error, Luckey argues that the trial court erred in

denying her motion to suppress the search of her apartment and all evidence obtained

therein.

A. Assignment of Error

{¶9} Appellate review of a trial court’s decision on a motion to suppress

“presents a mixed question of law and fact.” State v. Burnside, 2003-Ohio-5372, ¶ 8.

We accept the trial court’s findings as long as they are supported by competent,

credible evidence. State v. Rogers, 2022-Ohio-4535, ¶ 26 (1st Dist.). We then

independently determine whether the facts satisfy the applicable legal standard. Id.,

citing Burnside at ¶ 8.

{¶10} The Fourth Amendment protects against unreasonable searches and

seizures by the government. U.S. Const., amend. IV. Warrantless searches and

seizures “are per se unreasonable under the Fourth Amendment—subject only to a few

specifically established and well-delineated exceptions.” Katz v. United States, 389

U.S. 347, 357 (1967).

{¶11} “‘[W]arrants are generally required to search a person’s home . . . unless

the ‘exigencies of the situation’ make the needs of law enforcement so compelling that

the warrantless search is objectively reasonable under the Fourth Amendment.’” State

v. Buck, 2017-Ohio-8242, ¶ 19 (1st Dist.), quoting Brigham City v. Stuart, 547 U.S.

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OHIO FIRST DISTRICT COURT OF APPEALS

398, 403 (2006). Warrantless searches are justified where exigent circumstances exist

because “‘there is a compelling need for official action and no time to secure a

warrant.’” Id., quoting Michigan v. Tyler, 436 U.S. 499, 509 (1978).

{¶12} If a law enforcement officer “reasonably believe[s], based on specific

and articulable facts, that a person within the home is in need of immediate aid,” the

“emergency-aid” exception allows them “to enter a home without a warrant and

without probable cause.” Id. at ¶ 21. Courts look at the totality of the circumstances

to determine “whether police faced an emergency that justified acting without a

warrant.” Id. at ¶ 22, citing Missouri v. McNeely, 569 U.S. 141, 149 (2013). Law

enforcement officers do not need “ironclad proof” of a life-threatening emergency. Id.

at ¶ 23, quoting State v. Dunn, 2012-Ohio-1008, ¶ 19. Rather, the question is whether

a reasonable police officer would believe exigent circumstances exist. Id., citing Dunn

at ¶ 22.

{¶13} Here, Officer Drach believed that an autistic, nonverbal child had been

left home alone for over 13 hours. Under these circumstances, a reasonable police

officer would believe exigent circumstances exist and that waiting to obtain a warrant

could jeopardize the child’s health or safety. “Young children left unsupervised in a

house provide[] exigent circumstances to permit a warrantless entry into the premises

to locate the children, determine if they are in need of aid, and secure their safety.”

State v. Wyatt, 2004-Ohio-6546, ¶ 13 (9th Dist.); see State v. Edwards, 2010-Ohio826, ¶ 21 (11th Dist.).

{¶14} Therefore, Officer Drach’s warrantless entry of the apartment was

justified under the exigent circumstances exception to the Fourth Amendment’s

general prohibition against warrantless searches. The trial court did not err in denying

Luckey’s motion to suppress.

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OHIO FIRST DISTRICT COURT OF APPEALS

{¶15} The assignment of error is overruled.

III. Conclusion

{¶16} Having overruled Luckey’s sole assignment of error, we affirm the

judgment of the trial court.

Judgment affirmed.

BOCK, P.J., and MOORE, J., concur.

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