People v. Dallas

In People v. Dallas, 8 NY3d 890, 891, 865 N.E.2d 1, 832 N.Y.S.2d 893 (2007), the Court of Appeals held that there are three basic requirements for the application of the emergency doctrine: (1) the police must have reasonable grounds to believe that there is an emergency at hand and that there is an immediate need for their assistance for the protection of life or property; (2) the search must not primarily be motivated by an intent to arrest and seize evidence; (3) there must be some reasonable basis, approximating probable cause, to associate the emergency with the area or property to be searched.