“When the police arrived in response to the ‘disorderly’ call, there was no ongoing disorderly conduct or any indication of any other ongoing crime. Dickens appeared unharmed when she first opened the door to Officer Thornton’s knock, and she said nothing about the earlier disturbance as she walked past him to her apartment next door. The officers had no reasonable belief that contraband would be removed or destroyed; in fact, they had no belief any contraband would be found. There were three officers on the scene. A situation is not ‘urgent’ if ‘it appears that there is no imminent change to the circumstances about to occur and that the status quo largely can be maintained while the officers seek a warrant.’” Baskerville v. Commonwealth, 2023 Va. App. LEXIS 108 (Feb. 21, 2023).
Defendant was not prejudiced by post-trial disclosure of pole camera video of the house searched with a warrant because it was neither inculpatory nor exculpatory. United States v. Smart, 2023 U.S. App. LEXIS 3928 (8th Cir. Feb. 21, 2023).*