Commonwealth v. Woody
In Commonwealth v. Woody, 13 Va. App. 168, 170, 409 S.E.2d 170, 171 (1991), the Court noted two exceptions to this rule allowing for unannounced entries:
"(1) when officers 'have probable cause to believe that their peril would be increased if they announced their presence' or;
(2) when officers have probable cause to believe 'that an unannounced entry is necessary to prevent persons within from escaping or destroying evidence.'" Id. at 170, 409 S.E.2d at 171.