The San Diego County Fire Department got a call about a structure fire. When they arrived, it turned out to be a small fire in a brush pile in defendant’s backyard that was virtually out. The exigency dissipated and it was called in as such. Further entry into defendant’s backyard was then unwarranted. United States v. Vuytowecz, 2019 U.S. Dist. LEXIS 55931 (S.D. Cal. Apr. 2, 2019).
Defects in an arrest do not preclude trial on the offense. United States v. Belk, 2019 U.S. Dist. LEXIS 59116 (W.D. N.C. Apr. 5, 2019).*