Appellant's Brief - Washington State Courts

Furthermore, we have recognized two competing
policies in cases where the emergency exception is
invoked: (1) allowing police to help people who are
injured or in danger and (2) protecting citizens against
unreasonable searches. . . In each case, we must
balance these policies in light of the facts and
circumstances. (Cites omitted.)
Johnson, supra, at 417-18.
The courts must balance the individual's interest in freedom
from governmental intrusion against the governmental interests
which justify the intrusion. For example, the State interests of
"effective crime prevention and detection and exigent
circumstances" support a reasonable detention under Terry v. Ohio,
392 U .S. 1, 88 S. Ct. 1868, 20 L. Ed.2d 889 (1 968). State v,
Duncan, 146 Wn.2d 166, 176,43 P.3d 513 (2002).
In his brief, Smith discusses exigent circumstances,
including the six factors identified by the Cardenas court as those
the court uses in considering whether a warrantless entry was
justified:
(1) the gravity or violent nature of the offense with
which the suspect is to be charged; (2) whether the
suspect is reasonably believed to be armed; (3)
whether there is reasonably trustworthy information
that the suspect is guilty; (4) there is strong reason to
believe that the suspect is on the premises; (5) a
likelihood that the suspect will escape if not swiftly
apprehended; and (6) the entry is made peaceably.