The following excerpt is from USA v. Tisdale and Middleton, 195 F.3d 70 (2nd Cir. 1998):
The drugs at issue were described in the affidavit supporting the warrant as being in readily disposable form. Indeed, J.D. Gerald had recently thrown a bag containing fifty vials out the apartment's window, this apparently being a method of distributing drugs from the apartment to street sellers. Because the affidavit contained indicia pointing to the existence of particularized exigent circumstances, the officers' reliance on it was, at the least, not "entirely unreasonable." Leon, 468 U.S. at 923; see Rodriguez v. Butler, 536 F.2d 982, 987 (2d Cir. 1976) ("Arguably, the presence of easily disposable contraband without more constitutes a sufficient exigency to justify no-knock entry.").
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