Is a Warantless Search Justified In Exceptional Circumstances Involving Destruction of Evidence or Threat of Physical Harm ?

In Commonwealth v. Luv, 557 Pa. 570, 735 A.2d 87 (Pa. 1999), officers obtained a search warrant for defendant's home. See Luv, 735 A.2d at 89. Defendant then left his home and went to his girlfriend's home, where he parked his car. See id. Officers suspected that there were drugs in defendant's car and attempted to get a new search warrant for defendant's car. See id. Before they could do so, however, defendant drove away. See id. Believing that defendant was on his way to sell the drugs contained in the car, the officers stopped him before they could get a new warrant. See id. While "unforeseen circumstances involving the search of an automobile coupled with the presence of probable cause, may excuse the requirement for a search warrant". "Exigent circumstances arise where the need for prompt police action is imperative, either because evidence is likely to be destroyed, . . . or because there exists a threat of physical harm to police officers or other innocent individuals."