CA10: “not every domestic call justifies a warrantless entry,” but this one objectively did

“Although not every domestic call justifies a warrantless entry, see id. at 1244 (rejecting ‘a special rule for domestic calls because they are inherently violent’), the officers had information in addition to the call that indicated McCoy’s girlfriend’s safety could be at imminent risk. In particular, the mother demonstrated distress, described that she heard a threat against—and potential physical abuse of—his girlfriend that night, and made statements demonstrating McCoy had a reputation for violence. Cf. id. at 1243 (absence of a reputation for violence weighs against exigency). This information provided a reasonable basis for investigating further. …” McCoy v. Miller, 2016 U.S. App. LEXIS 9095 (10th Cir. May 16, 2016).