Brimage v. State
In Brimage v. State, 918 S.W.2d 466, 501-02 (Tex. Crim. App. 1996) the Court held that an officers may conduct a warrantless entry under the emergency doctrine to search for evidence that would lead to a kidnap victim or the victim himself.
In that case, prior to the officers' decision to search the defendant's home without a warrant, the officers knew:
(1) a woman had been missing for over two days;
(2) the defendant was acquainted with the woman and her car had been found unlocked with her purse in plain view and parked near defendant's residence in an area where, according to the woman's boyfriend, she never parked;
(3) the woman was observed on the morning of her disappearance driving near the defendant's house; (4) the woman was wearing a red blouse when last seen and a suitcase abandoned by the defendant contained a piece cut from a red blouse which appeared to have a bloodstain, scissors, and a piece of fabric from a pair of blue pajama pants;
(5) the defendant's uncle who, on his own, had entered defendant's home reported finding part of a pair of blue pajamas, other evidence of cut-up women's clothing, and evidence of a "violent struggle" in the master bedroom. Brimage, at 501-02.
The officers had an objective basis to reasonably believe the woman was injured, in need of assistance, and her disappearance was connected with the defendant's home.