What is the current state of the law on the grounds that destruction of evidence is insufficient to create exigent circumstances?

Precedent indicates not only that destruction of evidence was insufficient to create exigent circumstances, but also that danger to the officers was insufficient. In United States v. Jackson, 700 F.2d 181, 189 (5th Cir.1982), for instance, the rationale for entry was danger. The circumstances in our case differ materially from those in Jackson. Here the officers had no information indicating that anyone would be in the house, much less anyone who might be armed. In Jackson, by contrast, the agents had grounds to believe other persons present might entail danger because a suspect had told the agents that the two other participants were armed; even after arresting two unarmed suspects, the agents could point to articulable facts supporting their belief that other, armed suspects might be present.