What is the test for "exigent circumstances" in a criminal case?

The district court took too narrow a view of what may constitute exigent circumstances. The concept is not limited to circumstances indicating the destruction of evidence. As we pointed out in Reed, applying the standards the District of Columbia Circuit Court of Appeals announced in Dorman v. United States, 435 F.2d 385, 391 (1970), there are "various factors that may be used to determine whether 'exigent circumstances' are present." 572 F.2d at 424.

These include (1) the gravity or violent nature of the offense with which the suspect is to be charged; (2) whether the suspect "is reasonably believed to be armed"; (3) "a clear showing of probable cause ... to believe that the suspect committed the crime"; (4) "strong reason to believe that the suspect is in the premises being entered"; (5) "a likelihood that the suspect will escape if not swiftly apprehended"; and (6) the peaceful circumstances of the entry.

Id.; see also United States v. Campbell, 581 F.2d 22, 26 (2d Cir. 1978).