In what circumstances will police be able to search an apartment in a residential unit without a warrant?

In People v. Roberts (1956) 47 Cal.2d 374, 303 P.2d 721 the police went to an apartment building to question a suspect in a burglary. The apartment manager directed them to defendant's apartment and said he was sickly. The officers knocked on the door. They heard moans and groans and thought someone inside was in distress. The manager let them in. No one was inside. They found stolen property. (Id. at p. 376, 303 P.2d 721.) The denial of defendant's suppression motion was upheld

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In People v. Keener (1983) 148 Cal.App.3d 73, 195 Cal.Rptr. 733, the victim of a sexual assault directed the police to the house of her assailant. The assailant surrendered after three and one-half hours. After his surrender, the officers went and looked in the house for someone else, discovering incriminating evidence but not discovering any other persons. (Id. at p. 76, 195 Cal.Rptr. 733.) The appellate court upheld the search, stating, "[w]here there is reasonable cause to believe additional suspects or potential victims are in a residence, a warrantless entry is permissible." (Id. at p. 77, 195 Cal.Rptr. 733.)

A search of an apartment which had a fresh trail of blood leading to it was upheld in People v. Amaya (1979) 93 Cal.App.3d 424, 427, 155 [216 Cal.App.3d 374] Cal.Rptr. 783. No warrant is required "when, having come upon the scene of a crime, officers reasonably suspect a victim or victims might be inside a dwelling and in need of immediate aid." (Id. at p. 428, 155 Cal.Rptr. 783.)

The police in People v. Bradford, supra, 28 Cal.App.3d 695, 104 Cal.Rptr. 852 were in pursuit of "an armed robber who had demonstrated a great proclivity for shooting people." (Id. at p. 703, 104 Cal.Rptr. 852.) He took refuge in an apartment building with eight to twelve units. The police went to each unit, many residents consented to a search. In one unit no one answered the door. They entered and found incriminating evidence. The defendant rented this apartment. The search was upheld. In upholding the search, the appellate court stated, "In testing the reasonableness of the search we might ask ourselves how this situation would have appeared if the fleeing gunman armed with a shotgun had shot and possibly killed other officers or citizens while the officers were explaining the matter to a magistrate." (Id. at p. 704, 104 Cal.Rptr. 852.)