E.D.Mich.: A 16 year old girl, over the age of consent, was in a hotel room with a 45 year old man; that alone was not exigency

A 16 year old girl, over the age of consent, was in a hotel room with a 45 year old man. That alone did not create exigent circumstances. Certainly the parents would be concerned, but there was no evidence that she was being harmed or prostituted. The warrantless entry into the hotel room was unreasonable. United States v. Gordon, 2018 U.S. Dist. LEXIS 67460 (E.D. Mich. Apr. 23, 2018):

To summarize, in applying the Rohrig test, 1) there was no showing of any need for immediate action, such as any proof of harm or emergency; 2) the interest served in conducting a welfare check was not shown to be sufficiently important to overcome the presumption that a warrant is required to search a residence; and 3) the privacy interest in a residence is not outweighed by the government’s interest in performing a welfare check (when there is no evidence of imminent danger) and the Defendant did nothing to diminish his expectation of privacy. The Rohrig exigent circumstances test does not justify a warrantless entry.