Police get a domestic call, and when they get there “The officers heard a man say ‘shut the fuck up,’ a woman crying and whimpering, a loud thump, and then silence.” This was enough for exigency for an entry. State v. Clay, 293 Ore. App. 797, 2018 Ore. App. LEXIS 1067 (Sep. 8, 2018).
The IRS was investigating the defendant and gathered records from an employee. The IRS summons was validly issued for a valid purpose, and there’s no evidence at all that there was an end-run around the defendant’s Fourth Amendment rights. Inevitable discovery applies. United States v. Koerber, 2018 U.S. Dist. LEXIS 153231 (D. Utah Sep. 8, 2018).*