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United States v. McConney, 728 F.2d 1195, 1199 (9th Cir.)(1984)(no link)-EXIGENT CIRCUMSTANCES - Emergency conditions. 'Those circumstances that would cause a reasonable person to believe that entry (or other relevant prompt action) was necessary to prevent physical harm to the officers or other persons, the destruction of relevant evidence, the escape of a suspect, or some other consequence improperly frustrating legitimate law enforcement efforts.'
United States v. Grissett, 925 F.2d 776 (4th Cir. 1991)(no link)-The odor of marijuana coming from a motel room provided exigent circumstances to justify a warrantless entry.
US v. Cephas, No. 004780P (4th
Cir.)(2001)-The odor of marijuana coming from a residence
is probable cause that a crime was occurring. Warrantless entry is justified due
to exigent circumstances.
US v. Carter, 03a0017p.06 (6th Cir.)(2003)-Officers were investigating drug violations at a motel. They knocked on the door and the occupant opened. The officers smelled the odor of burned marijuana and saw a "blunt" (hollowed out cigar filled with marijuana) in plain view. The officers had the exigent circumstance of the possible rapid destruction of evidence. They were justified in entering the motel without a warrant and seize the "blunt".
United States v. Rhiger, 315 F.3d 1283(10th Cir.)(2003)-The defendant was observed by federal drug agents driving two companions to locations where materials were bought. The materials were components used to manufacture methamphetamine. The agents observed the material being carried into a house. They observed the house for about an hour. They then detected the odor of cooking meth coming from the house. The agents entered the house without a warrant fearing that an active lab could explode. The agents rendered the lab safe, secured the residence, and obtained a search warrant. The entry to the residence was lawful because it was a public safety exception under exigent circumstances.