What is the test for a warrant to enter into a person's home?

Defendant next contends that the officers' own conduct created the emergency and, therefore, the People cannot rely on exigent circumstances to justify the entry. "Just as exigent circumstances are an exception to the warrant requirement, a police-manufactured exigency is an exception to an exception." (United States v. Rico (5th Cir. 1995) 51 F.3d 495, 502 (Rico).) To invoke this exception, the police need not have acted in bad faith; rather, the court considers "the reasonableness and propriety of the investigative tactics that generated the exigency." (Id. at p. 502, internal quotations omitted.) We find the officers' actions in this case reasonable, and reject defendant's argument.