When police enter a house in an emergency, what is the scope of a search and seizure?

In Hodge v. State of Arkansas, 332 Ark. 377 (Sup. Ct. 1998), the court found the initial entry was valid based on exigent circumstances and held that the officers could seize whatever was in plain view. However, any subsequent search and seizure was limited to that which was in plain view when police entered in response to the emergency. The court distinguished the case from Mitchell v. State, 294 Ark. 264 (Sup. Ct. 1988), on the basis of the more serious circumstances. In Hodge, there was evidence that the family was missing, the accused stated they were dead and were in the house for several days, and the accused refused entry to an inner room. In regards to the smell, the officers may have suspected they would encounter a “dead body or two”, but it was not inconceivable that someone was alive.