Does the application of the Reed rule apply to a "knock and talk" visit to a suspect's home?

MultiRegion, United States of America

The following excerpt is from United States v. Allen, 813 F.3d 76 (2nd Cir. 2016):

Nor would application of the Reed rule create problems in cases in which probable cause is initially lacking, but develops during the course of a "knock and talk" visit to the suspect's home. If the circumstances create an exigency (say, the police interview yields the information that the suspect has a bomb inside his apartment), the exigent circumstances exception to the warrant requirement will permit the officers to cross the threshold and make the arrest. Absent such exigency, the availability of telephonic warrants, the ability of officers to surveil the home until a warrant is obtained, and the power to make a warrantless arrest if the suspect emerges from his home into the street, see United States v. Watson, 423 U.S. 411, 413, 41718, 96 S.Ct. 820, 46 L.Ed.2d 598 (1976), should permit effective arrests in virtually all cases.

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