Abstract
The US Supreme Court has determined that police officers may enter a home without a warrant when exigent circumstances exist. Lower courts have concluded that the police may not create their own exigent circumstances to justify entry, but have been unable to agree upon a test to determine if the police created an exigency. A lower court in King v. Kentucky found that police officers loudly knocking on a door and announcing ‘police’ constituted an impermissible police-created exigency. The US Supreme Court in Kentucky v. King disagreed when it determined that lawful conduct of the police outside a home is not the cause of possible unlawful conduct of occupants inside a home.
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