The availability of a telephonic or radio-obtained search warrant has changed the equation used by the courts in determining the exigency of a given situation which is claimed to justify a warrantless search. This Article will examine the change in the exigent circumstances equation. It will also focus on the impact of Rule 41(c)(2) on judicial remedies for warrantless searches. These remedies include suppression on traditional Fourth Amendment grounds, as well as the use of a federal court's supervisory power over the administration of criminal justice.
Edward F. Marek,
Telephonic Search Warrants: A New Equation for Exigent Circumstances,
27 Clev. St. L. Rev.
available at http://engagedscholarship.csuohio.edu/clevstlrev/vol27/iss1/5