What is the current state of the law on "exigent circumstances" where a police officer has to enter a house in the middle of the night in order to enter the front door?

While it is true that "exigent circumstances" can justify immediate entry, incantation of that phrase does not dissolve the shield that our law provides. We have held that even a mild exigency, like knowledge that a person is dangerous, can justify immediate entry where that can be done without any physical destruction of property. See United States v. McConney, 728 F.2d 1195, 1206 (9th Cir.1984) (en banc) (opening of an unlocked screen door). See also United States v. Arias, 923 F.2d 1387, 1391 (9th Cir.1991) (mild exigency is sufficient where entry can be made without physical destruction of property). That, of course, is not this case. Here the officers had to kick their way through a locked door in order to get at the home's occupants, who were still in bed.

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