What is the test for reasonableness in a search warrant application for a search of a home where drugs have been seized?

The court concluded that the fact the search involved narcotics created an exigent circumstance after the officers had knocked and announced their presence and purpose. "[C]ircumstances are exigent because a pusher may be near the point of putting his drugs beyond reach, [and] it is imminent disposal, not travel time to the entrance, that governs when the police may reasonably enter; since the bathroom and kitchen are usually in the interior of a dwelling, not the front hall, there is no reason generally to peg the travel time to the location of the door, and no reliable basis for giving the proprietor of a mansion a longer wait than the resident of a bungalow.... And 15 to 20 seconds does not seem an unrealistic guess about the time someone would need to get in a position to rid his quarters of cocaine." (United States v. Banks, supra, 540 U.S. at p. 40, 124 S.Ct. 521.) Thus, because the situation ripened into exigency after the officers knocked and announced their presence, the Fourth

[132 Cal.App.4th 245]

Amendment requirement of reasonableness had been satisfied, "even without refusal of admittance." (Id. at p. 43, 124 S.Ct. 521.)