How have courts interpreted the emergency exception to the search warrant requirement in domestic violence cases?

Pursuant to the emergency exception, police need not obtain a search warrant to enter a dwelling if "(1) considering the totality of the circumstances, law enforcement had an objectively reasonable basis for concluding that there was an immediate need to protect others or themselves from serious harm; and (2) the search's scope and manner were reasonable to meet the need." United States v. Snipe , 515 F.3d 947, 952 (9th Cir. 2008). Domestic violence cases do not "create a per se exigent need for warrantless entry." United States v. Brooks , 367 F.3d 1128, 1136 (9th Cir. 2004). Instead, we have found the emergency exception to the warrant requirement satisfied where police have an objectively reasonable belief that the victim is inside the home and in danger. See, e.g. , United States v. Black , 482 F.3d 1035, 1039 (9th Cir. 2007) (affirming application of the exigent circumstances doctrine when the defendant "could have returned to the apartment after [the victim's] 911 call, but before police arrived at the scene," which would have allowed the defendant to "pull [the victim] back into the apartment"); United States v. Brooks , 367 F.3d 1128, 1135 (9th Cir. 2004).