The following excerpt is from United States v. Delva, 858 F.3d 135 (2nd Cir. 2017):
The various situations in which exigent circumstances may justify a warrantless search "do not necessarily involve equivalent dangers," but in each the agents' action "is potentially reasonable because there is compelling need for official action and no time to secure a warrant. " Missouri v. McNeely , 569 U.S. 141, 133 S.Ct. 1552, 1559, 185 L.Ed.2d 696 (2013) (quoting Michigan v. Tyler , 436 U.S. 499, 509, 98 S.Ct. 1942, 56 L.Ed.2d 486 (1978) ); but see
[858 F.3d 153]
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