TN: Delivery of pseudo not exigency for warrantless entry but here they had independent source for warrant

Delivery of pseudoephedrine did not justify a warrantless entry into defendant’s house as an exigent circumstance. However, the officers had probable cause already, and there was an independent source for the information. Tennessee still follows Aguilar-Spinelli, and it requires “corroboration of more than a few minor elements of the informant’s information is necessary, especially if the elements relate to non-suspect behavior, … the events observed by the police need not supply probable cause by themselves or point unequivocally toward guilt.” Here, PC was satisfied. State v. Welch, 2016 Tenn. Crim. App. LEXIS 771 (Oct. 13, 2016).

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