In People v. Mitchell, 39 NY2d 173, 347 N.E.2d 607, 383 N.Y.S.2d 246 (1976), the New York Court of Appeals established guidelines for application of the "emergency" doctrine. Pursuant to the guidelines enunciated in Mitchell, for a warrantless entry to be justified as an "emergency": The police must have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property. The search must not be primarily motivated by intent to arrest and seize evidence. There must be some reasonable basis, approximating probable cause, to associate the emergency with the area or place to be searched." Id. at 178.