In Flippo v. West Virginia (1999) the U.S. Supreme Court took the opportunity to remind law enforcement officers that a warrantless entry into a private domain in response to an emergency situation is valid only as long as the emergency exists. Once action has been taken to provide medical services for any victims and the scene has been secured, any searches of the premises without a warrant are presumed unreasonable and a violation of the fourth amendment. In arson cases, the scope of the initial warrantless search is limited to that reasonably necessary to determine the fire's cause and origin and to guard against rekindling. The warrantless search must be limited to determining the cause of the fire. Regardless of the type of incident encountered by first-respondent officers, maintaining a presence at a secured scene that may involve a crime while making application for a search warrant is a legally permissible, routine practice. Exceptions to the search warrant requirement still apply, however. In addition to the existence of an emergency threat, other exceptions include consent to a search by a party who has the expectation of privacy at the scene, search incident to arrest, a motor vehicle, and inventory. Before a warrantless entering of a domain where persons clearly have an expectation of privacy, officers must weigh whether any of these exceptions exist. 31 notes