What is the test for warrantless searches in a domestic violence case?

Defendant cites People v. Ormonde (2006) 143 Cal.App.4th 282, which held that there were insufficient facts to establish exigent circumstances justifying a warrantless search, and that "the seriousness of the offense [i.e., domestic violence] does not, by itself, give rise to an exigent circumstance." (Id. at pp. 291.) In Ormonde, the domestic violence occurred outside the residence, and one of the officers testified that he did not think that there were people in the house. (Ibid.) The court stated that the objective facts circumstances known to the officers "fell short of supplying them with probable cause to

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