California, United States of America
The following excerpt is from People v. Dickson, 144 Cal.App.3d 1046, 192 Cal.Rptr. 897 (Cal. App. 1983):
15 At least one Federal court has expressly required both subjective motive and objective reasonableness to justify an emergency entry search. (Root v. Gauper (8 Cir.1971) 438 F.2d 361, 364, 365.)
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