What are "special facts" that prevent police officers from obtaining a search warrant for a motorcyclist's last drink?

^3. We found such "special facts" in People v. Toure (2015) 232 Cal.App. 4th 1096, 1104-1105, where the delay occasioned in subduing the combative defendant, and transporting him to the station after a brief investigation of an injury accident, prevented the officers from calculating backwards to determine when defendant had his last drink and what his blood alcohol level was at the time of the collision. (Id. at p. 1104.) Since that time, expedited procedures have been adopted for obtaining telephonic warrants under similar circumstances, which factored into the trial court's analysis in the present case.