In Cherry v. Virginia, 44 Va. App. 347, 605 S.E.2d 297 (Va. Ct. App. 2004), an officer knocked on the door of a known "problem" house because a stolen car was parked in the driveway.
The officer smelled marijuana when a woman opened the door. When the woman called inside that the police were at the door, the officer entered the house. Once inside, he saw cocaine and paraphernalia on a table, and seized cocaine from one of the persons seated at the table.
The Virginia Court reasoned that the warrantless entry was justified by exigent circumstances. It factored into its decision the officer's purpose in going to the house, which was to "investigate a non-drug-related offense." 605 S.E.2d at 362.
Because the officer "heard significant movement" in the house "immediately following" the notification that the police were at the door, the court concluded that the officer "acted reasonably in concluding that both the drugs and any occupants in possession of them were likely to be gone by the time he could obtain a warrant." Id. at 363.