What is the current state of the law on warrantless "protective sweep"?

There are several well-settled exceptions to the warrant requirement, one of which is the "protective sweep" rule under Maryland v. Buie (1990) 494 U.S. 325 (Buie). Under this rule, law enforcement officers may "take reasonable steps to ensure their safety after, and while making, [an] arrest [in a home]." (Id. at p. 334.) The high court identified two types of warrantless protective sweeps that are constitutionally permissible. In the first type, the officers may, "as a precautionary matter and without probable cause or reasonable suspicion, look in closets and other spaces immediately adjoining the place of arrest from which an attack could be immediately launched." (Ibid.) In the second type, officers may go beyond immediately adjoining areas and further investigate the premises, provided that there exist "articulable facts which, taken

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