What State v. Cooper Means for Fourth Amendment Appeals

On August 19, 2025, the Rhode Island Supreme Court issued its opinion in State v. Nathan Cooper (No. 2024-38-C.A.), a case that will have implications for how courts handle Fourth Amendment challenges on appeal.

At its core, Cooper asked whether police acted lawfully when they entered a Providence apartment without a warrant during what they described as a “wellness check.” The justices split, with the majority upholding the warrantless search under the emergency aid exception, and a strong dissent warning of dangerous erosion of constitutional protections.

The Case at a Glance

• Facts: Police were flagged down in Providence and told that a woman might have been killed and hidden inside an apartment refrigerator. Officers knocked repeatedly, heard a television, saw someone peek out the window, and ultimately forced entry. Inside, they discovered firearms and the woman's body.
• Trial: Cooper's trial lawyer - our law firm's own Kara Hoopis Manosh - argued the entry violated the Fourth Amendment and moved to suppress the evidence. The trial court denied the motion, and the jury convicted Cooper of second-degree murder, firearm charges, and discharging a gun during a violent crime .
• Appeal: The defense urged the Rhode Island Supreme Court to reverse, arguing no exigent circumstances existed because police had no objective reason to believe anyone was alive and in need of aid.

The Court's Ruling

Majority Opinion

The majority affirmed the conviction, holding that the totality of circumstances justified warrantless entry:

• A family member's urgent report was “tantamount to a 911 call.”
• Officers observed behavior that heightened concern—such as a figure peeking out the window but refusing to open the door.
• The possibility that the woman might still be alive gave police a duty to act immediately .

The Court extended this reasoning to the decision to open the refrigerator without a warrant, calling it “imperative” once officers entered and still did not know whether the woman was alive .

The Dissent

Justice Long dissented, relying heavily on U.S. Supreme Court and First Circuit precedent:

• Fourth Amendment principle: Warrantless entries into the home are “presumptively unreasonable.”
• Key point: A report that someone is already dead does not create an “ongoing emergency” justifying immediate entry.
• The dissent warned that relying on silence at the door or a loud TV as “suspicious” risks normal behavior being used to justify constitutional shortcuts .

Why This Case Matters for Criminal Defense Appeals

Cooper shows the thin line between emergency aid and unconstitutional entry. For defense lawyers handling appeals, several takeaways stand out:

1. Exigency is fact-intensive. Appellate courts will review the totality of circumstances, but defer to trial judges unless findings are clearly erroneous.
2. Subjective officer beliefs are not enough. The dissent reminds us that Fourth Amendment analysis must rest on objective facts, not speculation or hindsight.
3. The risk of precedent creep. Expanding what qualifies as an “emergency” can swallow the warrant requirement. Defense counsel must be vigilant in preserving these issues for appeal.
4. Future litigation. With the U.S. Supreme Court currently examining similar Fourth Amendment questions (e.g., State v. Case out of Montana, cert. granted 2025), Rhode Island's approach may not be the last word.

Final Thoughts

State v. Cooper is a sobering reminder of how high the stakes are in appeals cases. The majority saw urgency and danger; the dissent saw a constitutional violation. For criminal defense attorneys, this case underscores the importance of pressing suppression issues at trial and preserving them for appellate review.

As we continue this series, we'll keep exploring how appellate courts are shaping the future of criminal defense and what it means for protecting the rights of our clients.