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Court distinguished searches conducted for law enforcement purposes. The burden is on the state to show the need for the search and the reasonableness of the belief that a warrant could not be obtained. Police investigating a robbery saw a man run into an apartment and then heard a woman screaming. What Happens When You Face Out of State Criminal Charges? The pesky officers entered, he ran, any evidence found during the unlawful search cannot be used in the case against you. Any continued detention will be presumptively unreasonable without different information to justify the ongoing detention. Flares were used to route approaching traffic.