In United States v. Bute, 43 F.3d 531 (10th Cir. 1994), police officers observed an open garage door on a commercial building about 11 p.m. No vehicles were in the garage; no one was in or around the building; there was no sign of forced entry. Suspecting an earlier burglary or vandalism, one of the officers entered through the open garage door to check out the situation and immediately smelled a very strong odor. Unable to identify it, he opened each of three doors along the wall in the garage. Behind the third door, he found a methamphetamine lab. A search warrant was obtained and executed, and physical evidence was collected. As in this case, the district court in Bute denied the defendant's motion to suppress. Bute, 43 F.3d at 533-34. In Bute, the Tenth Circuit panel rejected what it termed a "wholesale exception" to the warrant requirement because "it makes no accommodation for the particular nature and circumstances surrounding individual buildings. " 43 F.3d at 537. "In so holding, we are mindful both of an officer's desire to protect the citizens and property on his or her patrol and the public's expectation regarding the protection of commercial property. In holding as we do, we do not suggest an officer can never enter commercial premises that are left open at night. We simply conclude a warrantless entry only is permitted under the Fourth Amendment when the officer has an objectively reasonable belief that an emergency exists requiring immediate entry to render assistance or prevent harm to persons or property within. While the infinite array of facts that may satisfy this requirement must be assessed on a case-by-case basis, it is clear that observing an open and unsecured building, without more, does not. In our judgment, the Fourth Amendment rights of all citizens outweigh the (lesser) expectations of some business owners that law enforcement authorities will enter and secure commercial premises found open at night." 43 F.3d at 539-40.