exigent circumstances exception (Massachusetts) · Go Syfert
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exigent circumstances exception in Massachusetts

15 Massachusetts opinions name it 2 courts 1975–2025 1 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (20)

CaseFollowedCited
Commonwealth v. Fordegreen
mass · 1975 · cited in 5 Massachusetts opinions naming this issue, 1995–2019
2 sentences

2019"Under the exigent circumstances exception to the warrant requirement, 'there must be a showing that it was impracticable for the police to obtain a warrant, and the standards as to exigency are strict.' " Id . at 97 , 112 N.E.3d 796 , quoting Commonwealth v. Forde , 367 Mass. 798 , 800, 329 N.E.2d 717 (1975).

2019"Under the exigent circumstances exception to the warrant requirement, 'there must be a showing that it was impracticable for the police to obtain a warrant, and the standards as to exigency are strict.' " Id . at 97 , 112 N.E.3d 796 , quoting Commonwealth v. Forde , 367 Mass. 798 , 800, 329 N.E.2d 717 (1975).

35
Commonwealth v. DeJesusgreen
mass · 2003 · cited in 1 Massachusetts opinions naming this issue, 2019–2019
2 sentences

2019"In the absence of a warrant, two conditions must be met in order for a nonconsensual entry to be valid" under the exigent circumstances doctrine: (1) "there must be probable cause" and (2) "there must be exigent circumstances." Commonwealth v. DeJesus , 439 Mass. 616 , 619, 790 N.E.2d 231 (2003).

2019"In the absence of a warrant, two conditions must be met in order for a nonconsensual entry to be valid" under the exigent circumstances doctrine: (1) "there must be probable cause" and (2) "there must be exigent circumstances." Commonwealth v. DeJesus , 439 Mass. 616 , 619, 790 N.E.2d 231 (2003).

11
Commonwealth v. Tyreegreen
mass · 2010 · cited in 1 Massachusetts opinions naming this issue, 2019–2019
2 sentences

2019Pursuant to both art. 14 and the Fourth Amendment, the exigent circumstances doctrine establishes another "well-recognized," King , 563 U.S. at 460 , 131 S.Ct. 1849 , yet "narrow" exception to the warrant requirement, see Tyree , 455 Mass. at 691 , 919 N.E.2d 660 .

2019Pursuant to both art. 14 and the Fourth Amendment, the exigent circumstances doctrine establishes another "well-recognized," King , 563 U.S. at 460 , 131 S.Ct. 1849 , yet "narrow" exception to the warrant requirement, see Tyree , 455 Mass. at 691 , 919 N.E.2d 660 .

11
Commonwealth v. Figueroagreen
mass · 2014 · cited in 1 Massachusetts opinions naming this issue, 2019–2019
2 sentences

2019See Commonwealth v. Figueroa , 468 Mass. 204 , 211-212, 9 N.E.3d 812 (2014).

2019See Commonwealth v. Figueroa , 468 Mass. 204 , 211-212, 9 N.E.3d 812 (2014).

11
Commonwealth v. Younggreen
mass · 1981 · cited in 1 Massachusetts opinions naming this issue, 2019–2019
2 sentences

2019See also Commonwealth v. Young , 382 Mass. 448 , 456, 416 N.E.2d 944 (1981) ("Exigencies which may justify a procedure **615 without warrant are a narrow category and must be established by the Commonwealth ..."); Commonwealth v. Forde , 367 Mass. 798 , 800, 329 N.E.2d 717 (1975) ("the standards as to exigency are strict").

2019See also Commonwealth v. Young , 382 Mass. 448 , 456, 416 N.E.2d 944 (1981) ("Exigencies which may justify a procedure **615 without warrant are a narrow category and must be established by the Commonwealth ..."); Commonwealth v. Forde , 367 Mass. 798 , 800, 329 N.E.2d 717 (1975) ("the standards as to exigency are strict").

11
cluster 1663green
· · cited in 1 Massachusetts opinions naming this issue, 2015–2015
1 sentence

2015Armijo Sanchez v. Peterson, 601 F.3d 1065, 1071 (10th Cir. 2010), cert. denied, 562 U.S. 1224 (2011) (“the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house” [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (placing search of home of detained man who had threatened his coworkers squarely within emergency exception, despite his not being home, as “[t]he authority to defuse a threat in an emergency nece

11
Commonwealth v. McCarthygreen
massappct · 2008 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015See also Commonwealth v. McCarthy, 71 Mass. App. Ct. 591, 594-595 (2008) (denying motion to suppress evidence found in defendant’s handbag when officer believed it may have contained cause of her overdose).

2015See also Commonwealth v. McCarthy, 71 Mass. App. Ct. 591, 594-595 (2008) (denying motion to suppress evidence found in defendant's handbag when officer believed it may have contained cause for her overdose). 8 b.

11
Mora v. City of Gaithersburg, Md.green
ca4 · 2008 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015Armijo Sanchez v. Peterson, 601 F.3d 1065, 1071 (10th Cir. 2010), cert. denied, 562 U.S. 1224 (2011) (“the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house” [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (placing search of home of detained man who had threatened his coworkers squarely within emergency exception, despite his not being home, as “[t]he authority to defuse a threat in an emergency nece

2015Consequently, the motion judge did not err in concluding that the officers were seizing the bottles in response to an emergency that encompassed both the condition of the defendant who was being taken to the hospital and the condition of the patients who were already there. (2011) (holding that "the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house" [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (pl

11
United States v. George Steven Mayesgreen
ca9 · 1982 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015Armijo Sanchez v. Peterson, 601 F.3d 1065, 1071 (10th Cir. 2010), cert. denied, 562 U.S. 1224 (2011) (“the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house” [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (placing search of home of detained man who had threatened his coworkers squarely within emergency exception, despite his not being home, as “[t]he authority to defuse a threat in an emergency nece

2015Consequently, the motion judge did not err in concluding that the officers were seizing the bottles in response to an emergency that encompassed both the condition of the defendant who was being taken to the hospital and the condition of the patients who were already there. (2011) (holding that "the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house" [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (pl

11
Richardson v. Stategreen
fla · 1971 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015Armijo Sanchez v. Peterson, 601 F.3d 1065, 1071 (10th Cir. 2010), cert. denied, 562 U.S. 1224 (2011) (“the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house” [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (placing search of home of detained man who had threatened his coworkers squarely within emergency exception, despite his not being home, as “[t]he authority to defuse a threat in an emergency nece

2015Consequently, the motion judge did not err in concluding that the officers were seizing the bottles in response to an emergency that encompassed both the condition of the defendant who was being taken to the hospital and the condition of the patients who were already there. (2011) (holding that "the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house" [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (pl

11
United States v. Moskow, Sigmundgreen
ca3 · 1978 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015Armijo Sanchez v. Peterson, 601 F.3d 1065, 1071 (10th Cir. 2010), cert. denied, 562 U.S. 1224 (2011) (“the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house” [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (placing search of home of detained man who had threatened his coworkers squarely within emergency exception, despite his not being home, as “[t]he authority to defuse a threat in an emergency nece

2015Consequently, the motion judge did not err in concluding that the officers were seizing the bottles in response to an emergency that encompassed both the condition of the defendant who was being taken to the hospital and the condition of the patients who were already there. (2011) (holding that "the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house" [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (pl

11
Commonwealth v. Molinagreen
mass · 2003 · cited in 1 Massachusetts opinions naming this issue, 2011–2011
1 sentence

2011In looking at the exigent circumstances exception to the warrant requirement, the Supreme Judicial Court has emphasized that the key underlying question is whether “it was impracticable for the police to obtain a warrant.” Commonwealth v. Molina, 439 Mass. 206, 209 (2003), quoting from Commonwealth v. Forde, 367 Mass. 798, 800 (1975).

11
Commonwealth v. Wigfallgreen
massappct · 1992 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See Commonwealth v. Huffman, 385 Mass. 122, 125-126 (1982); Commonwealth v. Hamilton, 24 Mass. App. Ct. 290, 293-295 (1987); Commonwealth v. Wigfall, 32 Mass. App. Ct. 582, 587-588 (1992); Commonwealth v. Street, 56 Mass. App. Ct. 301, 306-307 (2002).

11
Commonwealth v. Streetgreen
massappct · 2002 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See Commonwealth v. Huffman, 385 Mass. 122, 125-126 (1982); Commonwealth v. Hamilton, 24 Mass. App. Ct. 290, 293-295 (1987); Commonwealth v. Wigfall, 32 Mass. App. Ct. 582, 587-588 (1992); Commonwealth v. Street, 56 Mass. App. Ct. 301, 306-307 (2002).

11
Commonwealth v. Hamiltongreen
massappct · 1987 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See Commonwealth v. Huffman, 385 Mass. 122, 125-126 (1982); Commonwealth v. Hamilton, 24 Mass. App. Ct. 290, 293-295 (1987); Commonwealth v. Wigfall, 32 Mass. App. Ct. 582, 587-588 (1992); Commonwealth v. Street, 56 Mass. App. Ct. 301, 306-307 (2002).

11
Commonwealth v. Huffmangreen
mass · 1982 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See Commonwealth v. Huffman, 385 Mass. 122, 125-126 (1982); Commonwealth v. Hamilton, 24 Mass. App. Ct. 290, 293-295 (1987); Commonwealth v. Wigfall, 32 Mass. App. Ct. 582, 587-588 (1992); Commonwealth v. Street, 56 Mass. App. Ct. 301, 306-307 (2002).

11
Commonwealth v. Skeagreen
massappct · 1984 · cited in 1 Massachusetts opinions naming this issue, 2000–2000
1 sentence

2000See Commonwealth v. Shea, 18 Mass. App. Ct. 685, 694 (1984).

11
Michigan v. Tylergreen
scotus · 1978 · cited in 1 Massachusetts opinions naming this issue, 1997–1997
1 sentence

1997See Michigan v. Tyler, 436 U.S. 499 (1978).

11
Commonwealth v. Leegreen
massappct · 1992 · cited in 1 Massachusetts opinions naming this issue, 1995–1995
1 sentence

1995See Commonwealth v. Forde, 367 Mass. 798, 800-801 (1975); Commonwealth v. Lee, 32 Mass. App. Ct. 85, 88 (1992); Commonwealth v. Guaba, 417 Mass. at 754 .

11
United States v. Carignangreen
mad · 1967 · cited in 1 Massachusetts opinions naming this issue, 1975–1975
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
Kentucky v. King green
scotus · 2011
2 sentences

2019Pursuant to both art. 14 and the Fourth Amendment, the exigent circumstances doctrine establishes another "well-recognized," King , 563 U.S. at 460 , 131 S.Ct. 1849 , yet "narrow" exception to the warrant requirement, see Tyree , 455 Mass. at 691 , 919 N.E.2d 660 .

2019Pursuant to both art. 14 and the Fourth Amendment, the exigent circumstances doctrine establishes another "well-recognized," King , 563 U.S. at 460 , 131 S.Ct. 1849 , yet "narrow" exception to the warrant requirement, see Tyree , 455 Mass. at 691 , 919 N.E.2d 660 .

32011–2019
Commonwealth v. Arias green
mass · 2019
1 sentence

2025Arias, 481 Mass. at 615 , quoting Commonwealth v. DeJesus, 439 4 Mass. 616 , 619 (2003).

12025–2025
Commonwealth v. Alexis green
mass · 2018
1 sentence

2019"Under the exigent circumstances exception to the warrant requirement, 'there must be a showing that it was impracticable for the police to obtain a warrant, and the standards as to exigency are strict.' " Id . at 97 , 112 N.E.3d 796 , quoting Commonwealth v. Forde , 367 Mass. 798 , 800, 329 N.E.2d 717 (1975).

12019–2019
Missouri v. McNeely green
scotus · 2013
2 sentences

2019Six years ago, in Missouri v. McNeely, 569 U.S. 141 (2013), the Supreme Court clarified that the scope of the exigent circumstances exception to the warrant requirement articulated in Schmerber is not as broad as we concluded it was in Davidson.

2019Six years ago, in Missouri v. McNeely, 569 U.S. 141 (2013), the Supreme Court clarified that the scope of the exigent circumstances exception to the warrant requirement articulated in Schmerber is not as broad as we concluded it was in Davidson.

12019–2019
Commonwealth v. Streeter green
massappct · 2008
2 sentences

2017Finally, in Streeter, 71 Mass. App. Ct. at 437-438 , the result turns on a traditional exigent circumstances analysis. 6 While outside the defendant's apartment investigating an unrelated crime, the police smelled a strong odor of marijuana coming from inside the defendant's apartment.

2017Id. at 431 .

12017–2017
Rosado-Toro v. United States green
scotus · 2011
1 sentence

2015Armijo Sanchez v. Peterson, 601 F.3d 1065, 1071 (10th Cir. 2010), cert. denied, 562 U.S. 1224 (2011) (“the exigent circumstances exception permits warrantless home entries when officers reasonably believe that some actor or object in a house may immediately cause harm to persons or property not in or near the house” [emphasis in original]); Mora v. Gaithersburg, 519 F.3d 216, 225-226 (4th Cir. 2008) (placing search of home of detained man who had threatened his coworkers squarely within emergency exception, despite his not being home, as “[t]he authority to defuse a threat in an emergency nece

12015–2015
Woodford, Warden v. Wai Silva green
scotus · 2002
1 sentence

2011Citing Commonwealth v. Forde , the defendant did argue below that police lacked “sufficient justification for the failure to obtain a warrant." To support its position that the issue is before us on substantial risk review, the Commonwealth cites to Commonwealth v. Vuthy Seng, 436 Mass. 537, 550 , cert. denied, 537 U.S. 942 (2002).

12011–2011
Commonwealth v. Vuthy Seng green
mass · 2002
1 sentence

2011Citing Commonwealth v. Forde , the defendant did argue below that police lacked “sufficient justification for the failure to obtain a warrant." To support its position that the issue is before us on substantial risk review, the Commonwealth cites to Commonwealth v. Vuthy Seng, 436 Mass. 537, 550 , cert. denied, 537 U.S. 942 (2002).

12011–2011
Commonwealth v. Navarro green
massappct · 1995
1 sentence

2005Id. at 620-624 & nn.3, 8.

12005–2005
Commonwealth v. Guaba green
mass · 1994
1 sentence

1995See Commonwealth v. Forde, 367 Mass. 798, 800-801 (1975); Commonwealth v. Lee, 32 Mass. App. Ct. 85, 88 (1992); Commonwealth v. Guaba, 417 Mass. at 754 .

11995–1995
Malley v. Briggs green
scotus · 1986
1 sentence

1991Schmerber , on the other *884 hand, dealt with the exigent circumstances exception to the warrant rule, and, while the Court in that case was concerned with the intrusive nature of searches “involving intrusions beyond the body’s surface,” id. at 769 , it did not state, in its holding or in dictum, that such searches are per se unconstitutional.

11991–1991
Carroll v. United States green
scotus · 1925
11977–1977
Ludlow v. State green
ind · 1974
11975–1975

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 269, § 10 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 133 (1975–2025) PA 115 (1974–2026) OH 106 (1978–2025) CA 82 (1977–2026) WA 71 (1973–2022) NJ 57 (1970–2026) WI 54 (1982–2026) IL 50 (1977–2025) IA 46 (1977–2025) MI 45 (1981–2025) OR 41 (1972–2021) CO 41 (1977–2026) FL 40 (1981–2024) NM 35 (1975–2022) VA 34 (1992–2026) ID 33 (1978–2026) MN 31 (1984–2025) NY 31 (1973–2024) TN 28 (1996–2020) IN 28 (1985–2025) SC 24 (1986–2023) MO 23 (1985–2019) CT 23 (1978–2023) ME 22 (1974–2024) UT 19 (1991–2025) ND 18 (1984–2019) LA 18 (1981–2026) DC 17 (1976–2018) GA 17 (1975–2026) KS 16 (1990–2022) MD 15 (1973–2026) MA 15 (1975–2025) NH 14 (1974–2018) AZ 13 (1984–2018) AL 13 (1976–2015) NC 13 (1983–2024) MT 13 (1996–2024) DE 11 (1974–2026) SD 11 (1978–2021) RI 10 (1983–2025) WV 9 (1985–2023) KY 9 (1979–2025) AR 7 (1992–2005) NV 7 (1989–2025) HI 6 (1981–2002) AK 5 (1993–2009) VT 5 (1982–2023) MS 4 (1997–2017) VI 2 (1984–2012) WY 2 (1987–2017) NE 2 (2015–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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