W.D.Tex.: Exigencies of crack deal going down in hotel room excused warrant

There was more than probable cause, and inference on inference here showed it on the totality. A crack cocaine deal going down in a hotel room proved to be exigent circumstances. It would take two hours to get a search warrant, but this was developing fast. Also, the officers did not manufacture the exigency. United States v. Scott, 2014 U.S. Dist. LEXIS 187633 (W.D. Tex. Sept. 2, 2014)*:

However, exigent circumstances arose in the reasonable belief of the detectives before the detectives could obtain a warrant, which required entering before the warrant could be obtained. “It is ‘axiomatic that agents are not required to obtain a search warrant as soon as it is practicable to do so.’ Agents ‘conducting an ongoing investigation do not need to obtain a warrant at the first opportunity. If exigencies arise before agents can obtain a warrant, they can justifiably act.'” United States v. Rodea, 102 F.3d 1401, 1409 (5th Cir. 1996) (citations omitted). As Detective Dolan’s testimony reflected, this operation moved very quickly.