Problem
Charged with aggravated bank robbery in St. Peters, Mississippi, defendant Golden filed a motion to suppress $12,000 in bank currency seized from his hotel room. The motion to suppress evidence hearing disclosed that at 2:00AM one Saturday morning, someone in the hotel reported a serious fight to the police. The police arrived within minutes and found a person lying on the floor in a hallway of the hotel with a fatal gunshot wound.
The hotel front desk clerk advised the officers that Golden had gone upstairs with a gun, apparently wounded. The officers and clerk went to Golden's room, knocked on the door, and received no answer. At the officers' request, the hotel clerk unlocked the door. Inside, the officers observed a blood-stained shirt on the bed. After looking under the bed and in the closet and bathroom, they concluded that Golden was not in the room.
Continuing to search the room, the officer opened a suitcase that was in the closet and discovered $12,000 under some clothing. Golden was arrested at a nearby emergency room and after bank employees identified the marked money as stolen.
First, did the officers have exigent circumstances to search Golden's hotel room? Justify your answer.
Second, if the officers had exigent circumstances to search Golden's hotel room, what were the police searching for and what was the permissible scope of the search?
Third, was the search of the suitcase within the permissible scope of the search? Justify your answer.