Full opinion text
LYNCH, Circuit Judge. This appeal presents interesting questions about the application of the Fourth Amendment when an anonymous tipster informs police that there is a dead body in a motel room. A series of events cascaded from that tip, resulting in the arrests of Rodger Beaudoin and Robert Champagne on various drug-related charges and a federal prosecution for conspiracy to distribute cocaine and crack and for possession of crack with intent to distribute. 21 U.S.C. §§ 841(a)(1), 846. Before trial, the defendants each moved to suppress all of the evidence that the police had found in a search of them and their motel room, including knives, drugs, drug paraphernalia, and large amounts of cash. After an evi-dentiary hearing, the trial court, in a thoughtful opinion, denied their motions. The defendants pled guilty but preserved the right to challenge the suppression ruling on appeal, which they now exercise. Champagne also appeals from a sentence enhancement. We affirm both the denial of the suppression motions and the sentence enhancement. I. Background Facts The facts are taken from the suppression hearing, as found by the district judge, and supplemented from the record. At 5:15 in the morning on July 24, 2001, the Manchester, New Hampshire Police Department informed the Hookset Police Department that a dispatcher had just received a 911 call during which an unidentified person reported “a drug deal gone bad at the Kozy 7 Motel, Room 10” in Hook-sett. The caller said “I think there is a dead body in there,” and then hung-up before any follow-up questions could be asked. Three Hooksett officers, Sergeant Chamberlain and Officers Pinardi and Sherrill, were immediately dispatched to the motel, about three miles away. Officer Pinardi understood that the information was that “a drug deal [had] gone bad, during which a person was allegedly shot and there was a dead body.” The call transcript itself contains nothing about a shooting, but Pinardi heard the dispatcher conveying the information to Chamberlain. The motel was not upscale and was the sort of place that police had visited before in connection with criminal activity. The officers arrived several minutes later. They did not attempt to see the motel manager to ask if there was any unusual activity in the room, but instead • went straight to the room that the caller had identified. The officers noticed that a light was on in Room 10, but that all of the other rooms were dark. The curtain of the window to Room 10 was closed. The uniformed officers approached the room; Officers Pinardi and Sherrill took positions on either side of the doorway, while Sergeant Chamberlain' stood farther back on the opposite side of the motel room’s window. Pinardi stood to the left of the door for “officer safety reasons.” Among other things, in that position he “would be able to see inside the room, see what was going on, and also ... be able to get out of the way if ... the door ... swung open.” Officer Sherrill instinctively stood in front of the door, but he moved to the right after Sergeant Chamberlain told him to step away from the door. Sergeant Chamberlain chose a position to the right of the door, by the window, to get “a little concealment or whatever if something did happen in the room, whether there was going to be a shoot-out or whatever.” He was concerned for his own safety because of the report that there was a dead body in the room. Chamberlain, with a view of the window, saw some movement behind the window, and the officers heard some rustling from the room. Pinardi knocked on the door. A man (who was later identified as Beau-doin) drew back the curtains of the window and peered outside toward Chamberlain. There was sufficient light to see the uniformed officers. Chamberlain then identified himself and the others as Hooksett police officers and asked the man to go to the door so they could speak with him. The man, Beaudoin, opened-the door, but only wide enough so his face could be seen. Both the interior door and an outer screen door were opened. Sergeant Chamberlain could not recall if Beaudoin pushed the screen door entirely open, or if Beaudoin pushed the screen door part way open and an officer held it open. Officers Chamberlain and Pinardi presented slightly varying accounts of what transpired next. These differences prove to be immaterial. Officer Pinardi testified that once Beaudoin opened the door, the officers explained to him that they were investigating a crime and had heard that someone had been shot in the room. Pi-nardi said that he then asked Beaudoin if he could “just come out here” so the police could talk to him and that Beaudoin did so voluntarily. Sergeant Chamberlain, however, testified that he asked Beaudoin to step outside so they could talk to him, which Beaudoin did, and only then explained why the police were there. Either way, Beau-doin stepped outside, leaving the door behind him sufficiently open so that Pinardi could see inside the room. Whether Beau-doin felt free not to step outside is an open question. Once Beaudoin was outside, Sergeant Chamberlain asked him if he was carrying any weapons. Beaudoin said that he had a knife in his left rear pocket and started to reach for it. Sergeant Chamberlain said that he would remove the knife, ordered Beaudoin to put his hands on the wall, and proceeded to pat him down. During the pat down, Sergeant Chamberlain patted Beaudoin’s left rear pocket and felt three objects: an object that seemed to be a knife and two long and hard cylindrical objects that he was unable to identify. Chamberlain reached into the pocket and removed a knife, two glass tubes, and three plastic balls containing crack cocaine. The glass tubes and crack cocaine were contained in one plastic bag. Chamberlain placed Beaudoin under arrest and finished the pat down. He found $300 in Beau-doin’s right front pocket. While Sergeant Chamberlain was frisking Beaudoin, Officer Pinardi made eye contact with a second man in the motel room, later identified as Champagne, through the open door. Once Champagne saw Pinardi, Champagne hurried across the room toward the far wall and began to shuffle through some items on top of a dresser and to reach into his pockets. Pi-nardi thought it odd that the man, upon seeing the police, did not come toward them to ask why they were there. Pinardi feared that Champagne was either searching for a weapon or trying to hide evidence, so he and Officer Sherrill entered the motel room and directed Champagne away from the dresser and toward the middle of the room. Pinardi explained to Champagne that the officers had received a report that there was a dead person in the motel room. Champagne denied that there was a dead body. Pinardi asked Champagne if he had any weapons. Champagne, who was nervous, said that he did not, but Officer Pinardi saw that Champagne had a knife clipped to one of his pockets. Pinardi removed the knife and conducted a protective frisk, holding Champagne’s arms behind his back. During the frisk, Champagne became increasingly fidgety and kept attempting to free his hands to reach into the pockets of his pants. Pinardi patted Champagne’s right front pocket and felt several long, hard cylinders, which he feared could be small pen guns or knives. Champagne became even more fidgety when Pinardi patted that pocket. When Champagne refused to comply with Pinar-di’s instruction to stop moving his hands, Pinardi and Sherrill pushed him face down on the bed and handcuffed him. Pinardi told Champagne that he was not under arrest but was being restrained so Pinardi could safely ascertain the nature of the situation in the room. Officer Pinardi still had not looked in the bathroom and had no idea whether there was a dead body inside. Pinardi and Sherrill helped Champagne to his feet and asked him what was in his front pocket. When Champagne said that he did not know, Pinardi stretched open Champagne’s pocket so he could see inside it. With the aid of a flashlight held by Sherrill, Pinardi saw several crack pipes, which were the long cylindrical objects that he had feared were weapons, as well as a substance that later proved to be crack-cocaine. Pinardi seized these items and continued his frisk, finding yet more crack and a wad of cash. After completing these searches, the officers searched the rest of the motel room for a dead body. When they did not find a body, the officers left behind the contraband they had found and brought Beau-doin and Champagne to the police station. Once a search warrant was obtained, the police returned to the motel room and took the contraband found in the searches, as well as additional drug paraphernalia, into police custody. They also found by the door a plugged-in skill saw with its safety cover duct-taped up. II. Procedural History Each defendant was indicted on charges of conspiracy to distribute cocaine and crack and possession of crack with intent to distribute. 21 U.S.C. §§ 841(a)(1), 846. Champagne was also indicted on charges of obtaining proceeds from the distribution of crack. Id. § 853. Both defendants moved to suppress all of the evidence that had been seized at or near the motel room, including the drugs found on them and the contraband discovered inside the motel room. The prosecution argued that the request that Beaudoin step out of the motel room doorway was justified by exigent circumstances, such, as a Terry stop, and that the evidence subsequently found was admissible under the inevitable discovery doctrine. The trial judge conducted an evidentiary hearing on December 5, 2001. After hearing the testimony of Officer Pi-nardi and Sergeant Chamberlain and reviewing a transcript of the 911 call and copies of the police reports, the district court judge denied both defendants’ motions. The judge held that the officers’ initial request that Beaudoin exit his motel room and their later entry into the room were both justified by the emergency assistance exception to the warrant requirement because the officers could reasonably have believed that a person inside of the motel room was in need of emergency aid. The defendants' then pled guilty to the crimes charged in the indictment, but reserved their right to appeal the district court judge’s denial of their suppression motions. Beaudoin was sentenced to fifty-seven months in prison to be followed by four years of supervised release, and Champagne, to 151 months in prison to be followed by five years of supervised release. In sentencing Champagne, the judge imposed a two-point increase in his offense level based upon his possession of the electric saw, which the judge deemed to be a dangerous weapon. U.S.S.G. § 2Dl.l(b)(l). III. Analysis A. Fourth Amendment Issue The ultimate conclusion on whether the police violated the Fourth Amendment is reviewed de novo. Ornelas v. United States, 517 U.S. 690, 697, 116 S.Ct. 1657, 134 L.Ed.2d 911 (1996). We defer to the district court’s factual findings, which we accept. This case does not turn on any disputed issue of fact. .The Fourth Amendment protects people from unreasonable searches and seizures by the government. A warrant-less search involving an intrusion into someone’s home is presumptively unreasonable under the Fourth Amendment. Groh v. Ramirez, - U.S. -, - - -, 124 S.Ct 1284, 1290-91, 157 L.Ed.2d 1068 (2004); Steagald v. United States, 451 U.S. 204, 211-12, 101 S.Ct. 1642, 68 L.Ed.2d 38 (1981). The reasonableness of a search depends entirely on the context in which it takes place; different Fourth Amendment doctrines as to reasonableness have evolved to fit different contexts. 'One set of variants in these doctrines is the degree of the privacy expectations involved. For example, expectations of privacy in a commercial establishment are not strong. See New York v. Burger, 482 U.S. 691, 700, 107 S.Ct. 2636, 96 L.Edüd 601 (1987). Privacy expectations in one’s home, by contrast, are quite strong. See Groh, - U.S. at - - -, 124 S.Ct. at 1290-91; Kyllo v. United States, 533 U.S. 27, 40, 121 S.Ct. 2038, 150 L.Ed.2d 94 (2001). As such, searches usually may not be made in a person’s home unless the police have obtained a search warrant based on probable cause. Payton v. New York, 445 U.S. 573, 586-87, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980). By analogy, this rule is usually extended to searches in a person’s hotel or motel room, which is a sort of temporary home. See Stoner v. California, 376 U.S. 483, 490, 84 S.Ct. 889, 11 L.Ed.2d 856 (1964); United States v. Baldacchino, 762 F.2d 170, 175-76 (1st Cir.1985). Another set of contextual variants are grouped under the doctrine of exigent circumstances. The exigent circumstances usually recognized include: (1) risk to the lives or health of the investigating officers; (2) risk that the evidence sought will be destroyed; (3) risk that the person sought will escape from the premises; and (4) “hot pursuit” of a fleeing felon. See United States v. Tibolt, 72 F.3d 965, 969 (1st Cir.1995). Several courts have recognized another type of exigent circumstance: an emergency situation in which police must act quickly to save someone’s life or prevent harm. See United States v. Holloway, 290 F.3d 1331, 1337 (11th Cir.2002); United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000); Seymour v. Walker, 224 F.3d 542, 556 (6th Cir.2000); Tierney v. Davidson, 133 F.3d 189, 196 (2d Cir.1998); Wayne v. United States, 318 F.2d 205, 212 (D.C.Cir.1963) (Burger, J.). This court has not had occasion to address the emergency doctrine. Recognition of some type of emergency doctrine is entirely consistent, though, with the logic of the traditional exigency exceptions to the warrant requirement. This court implicitly said as much in Bilida v. McCleod, 211 F.3d 166 (1st Cir.2000), holding that “[w]arrantless entries are most often justified by ‘exigent circumstances,’ the best examples being hot pursuit of a felon, imminent destruction or removal of evidence, the threatened escape by a suspect, or imminent threat to the life or safety of the public, police officers, or a person in residence.” Id. at 171 (emphasis added). And the Supreme Court, in dicta, has said that the Fourth Amendment “does not bar police officers from making warrantless entries and searches when they reasonably believe that a person within is in need of immediate aid.” Mincey v. Arizona, 437 U.S. 385, 392, 98 S.Ct. 2408, 57 L.Ed.2d 290 (1978). In the end, this case involves the intersection of several Fourth Amendment doctrines, most notably, those of exigent circumstances, emergencies, and Terry-type temporary detentions during investigations. Generally, under the emergency doctrine, there must be a reasonable basis, sometimes said to be approximating probable cause, both to believe in the existence of the emergency and to associate that emergency with the area or place to be searched. 3 W. LaFave, Search & Seizure § 6.6(a) (3d Ed.1996); People v. Mitchell, 39 N.Y.2d 173, 177-78, 383 N.Y.S.2d 246, 347 N.E.2d 607 (1976). The analysis must be with reference to the circumstances confronting the officer, including, as one commentator has put it, “the need for a prompt assessment of sometimes ambiguous information concerning potentially serious consequences.” LaFave, supra, § 6.6(a); see also Wayne, 318 F.2d at 212 (Burger, J.). The facts also raise the classic exigent circumstances situation, of a risk to the safety of police officers; the officers were investigating a report of both drug activity and possible deadly criminal activity in the room. Traditional exigent circumstances justify a warrantless search when there is reasonable suspicion that a person poses a threat to the lives or safety of police officers and there is probable cause to believe that a crime has been committed. McCabe v. Life-Line Ambulance Serv., 77 F.3d 540, 545 (1st Cir.1996); United States v. Tibolt, 72 F.3d 965, 969 (1st Cir.1995); Hegarty v. Somerset County, 53 F.3d 1367, 1376 (1st Cir.1995). But whether or not probable cause for a crime exists, the inquiry determining the existence of an exigency is essentially one of reasonable suspicion. See United States v. Soto-Beniquez, 356 F.3d 1, 36 (1st Cir.2003); United States v. Lopez, 989 F.2d 24, 26 (1st Cir.1993). Further, the government correctly suggests that the detention of Beaudoin was analogous to a Terry stop. Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968). Terry stops, designed to protect police officers in their investigations, may occur when there is reasonable suspicion to believe that criminal activity is afoot, even where there is not probable cause to arrest. See United States v. Lee, 317 F.3d 26, 31 (1st Cir.2003) (warrantless investigatory stops are allowable if, and to the extent that, police officers have reasonable suspicion of wrongdoing that is based on specific, articulable facts); LaFave, supra, § 9.4; Florida v. Royer, 460 U.S. 491, 498, 103 S.Ct. 1319, 75 L.Ed.2d 229 (1983). Reasonable suspicion is a less demanding standard than probable cause. United States v. Golab, 325 F.3d 63, 66 (1st Cir.2003). Once the stop has occurred, an officer may search a suspect’s person for weapons based on reasonable suspicion that the person is armed and dangerous. Terry, 392 U.S. at 27, 88 S.Ct. 1868. When the officer suspects a crime of violence, the same information that will support an investigatory stop will, without more, support a protective search. Id. at 33, 88 S.Ct. 1868; United States v. Scott, 270 F.3d 30, 41 (1st Cir.2001). Defendants argue only that Terry does not justify a command to step out of the doorway. They do not argue that Terry precluded the police, standing outside and knocking, to ask the man (who opened the curtain) to go to the doorway to talk to the police. Nor do they argue that Beaudoin went involuntarily to the door and opened it. So this is more like a situation in which a person voluntarily stops, and then the police take reasonable steps, during that temporary stop, to protect themselves during the questioning. These doctrines are not firm-line tests. “The governing caselaw under the Fourth Amendment does not yield very many bright line rules. This is not surprising since the ultimate touchstone is one of reasonableness.... ” Joyce v. Town of Teuksbury, 112 F.3d 19, 22 (1st Cir.1997). When the police were informed of the anonymous call reporting both drug dealing and a dead body, they were certainly justified’ in promptly going to the motel to investigate. Not surprisingly, nothing visible at the motel either disproved the report nor particularly confirmed it. As such, it was reasonable for the police, seeing a light on at 5:30 a.m. in the room that the anonymous caller had identified, to assume that someone was in the room and to knock on the door. Once the police heard movement in the room and saw someone open the curtain, it was reasonable for them to ask that person to go to the door so they could speak with him. See Illinois v. Lidster, - U.S. -, 124 S.Ct. 885, 890, 157 L.Ed.2d 843 (2004) (law enforcement officials can permissibly “seek the voluntary cooperation of members of the public in the investigation of a crime”). Beaudoin did not fully open the door in response to the officers’ request; rather, he opened it just enough so that his face was visible. The officers could not see Beaudoin’s hands, nor could they see any part of the room that was within easy reach of the doorway. It is at this point that the issue of officer safety arose. The relevant facts are those that were known to the police at the time of the exigency. See Banks, 124 S.Ct. at 527. The police knew that a 911 call had been made within the half-hour stating that both a crime (drug dealing) and a death (possible crime) had happened in the motel room. If the phone report was true, the man in the doorway probably was involved in either or both of the reported activities and might even be a murderer; the man might well be armed and might have companions in the room. The association between drug dealing and guns is well known. The officers could not verify that the man was not armed because of the way he had opened the door, nor could they tell if he had a weapon close at hand. The partially opened doorway to the small motel room was not a safe place for the police to investigate whether the man was armed, in this situation. Additionally, the officers had heard noises from inside the room and thus had reason to suspect that at least one other person besides the man at the door was inside. In the end, this case turns on whether it was reasonable for Sergeant Chamberlain to ask Beaudoin to step out of the doorway. It matters not, in these particular circumstances, whether the request was in essence a command. We will assume ar-guendo that Beaudoin did not feel free to ignore the officers’ summons. We also assume arguendo that the statement to Beaudoin to step outside was a “seizure,” though this is not free from doubt. The issue is whether the command was justified under the combination of the three doctrines. The Fourth Amendment question is not whether Beaudoin acted reasonably that morning; the question is whether the officers’ response to Beaudoin’s actions was reasonable in context. Nor is the issue whether the officers had probable cause to arrest Beaudoin and enter the room based solely on the anonymous tip; we need not decide that. See Florida v. J.L., 529 U.S. 266, 270-71, 120 S.Ct. 1375, 146 L.Ed.2d 254 (2000). There may, of course, be exigent circumstances posing a threat to officers and justifying reasonable responses even in the absence of probable cause to arrest. The notion is abhorrent that police who are investigating a crime and suddenly find themselves at risk are precluded from acting reasonably in response to that risk merely because they have not yet established probable cause to make an arrest for a crime. Finally, the question presented here is not whether the anonymous tip alone, absent any risk of injury to the officers, justified the command to step out of the doorway. Nor is any abstract issue raised about the application of Terry to persons in doorways absent the emergency and exigent circumstances present here. As the Supreme Court has emphasized, determining whether the officers’ actions were reasonable in the context of exigent circumstances requires balancing the need for the warrantless search or seizure against the harm to the individual whose privacy is being intruded upon in light of all the circumstances. See United States v. Banks, - U.S. -, 124 S.Ct. 521, 525, 157 L.Ed.2d 343 (2003) (whether exigent circumstances justify police action depends on a reasonableness inquiry based on the totality of the circumstances). Courts engaging in this balancing must be wary of overlaying a “categorical scheme on the general reasonableness analysis” and thus “distort[ing] the ‘totality of the circumstances’ principle, by replacing a stress on revealing facts with resort to pigeonholes.” Id. at 528. Here, the harm to Beaudoin in being commanded (assuming he was commanded) to step out of the doorway of his motel room was relatively small. The police did not order Beaudoin out of the doorway until he had voluntarily opened the door and spoken with them. To the extent this was a seizure, it was more akin to the temporary detention involved in a Terry stop. The police did not enter the motel room here, but merely told (or perhaps, requested) Beaudoin to step outside of his doorway. This is entirely in keeping with the basic rationale of Terry: a brief “seizure” in these circumstances protected police safety and facilitated the investigation while minimizing the intrusiveness of the invasion on Beaudoin’s privacy. We do not say that Beaudoin relinquished all expectations of privacy merely by opening his door; still, it was less intrusive for the police to tell him to step outside at that point than it would have been if Beaudoin had not himself come partially outside by opening the door. Cf. U.S. v. Santana, 427 U.S. 38, 42, 96 S.Ct. 2406, 49 L.Ed.2d 300 (1976) (there is no expectation of privacy in the doorway to one’s home because one is knowingly “exposed to public view, speech, hearing, and touch as if [one] had been standing completely outside [one’s] house”). A police command to step out of the opened door of one’s motel room is, nonetheless, a non-trivial invasion of privacy. But balanced against the objective safety concerns of the officers here, and in light of the call about an emergency, it was reasonable. See United States v. Sargent, 319 F.3d 4, 10-12 (1st Cir.2003) (officers had reasonable suspicion of danger in executing a search warrant at an apartment that they knew contained drugs and numerous knives when there was a five-second delay between the police announcement of their presence and the opening of the door); United States v. Bartelho, 71 F.3d 436, 442 (1st Cir.1995) (noting the importance of the police officers’ safety in the exigent circumstances analysis). Telling Beaudoin to step outside was an effective way for the officers to alleviate their significant safety concerns. First, it assured the officers that Beaudoin was not holding a loaded gun in his hands and that he was not within easy reach of a weapon. Second, it allowed the police to ask Beau-doin some questions while putting some distance between themselves and other persons potentially in the room. Finally, asking Beaudoin out of the room allowed the police to perform a pat down unhindered by a door frame and to subdue Beaudoin if necessary. An argument may be made that there were alternatives available to the police. The officers could have attempted first to contact the motel manager or to telephone to see if there were people inside of the room. But most of those alternatives were available several steps earlier in the process and were hardly required. Realistically, they were no longer available once Beaudoin opened the door as he did. There is also a suggestion that the officers should not have asked Beaudoin to step out of the doorway at all once he opened it; they should have simply retreated from the area. The officers had reasons to fear being shot if they retreated. The police would have been foolish either to back away or to turn their backs on Beaudoin. For the officers to ascertain whether he had weapons, in light of the information they had, was eminently sensible. Moreover, delay risked the life of the person in the room reported to be dead, if there were such a person. None of the officers’ actions after Beaudoin stepped out of the doorway justifies suppressing the evidence. Once Beaudoin stepped out of the doorway, it was reasonable for the officers to ask him if he had a weapon. And when Beaudoin said that he had a knife and reached for his pocket, it was reasonable for the officers to do a quick pat down. After finding the knife and two drug pipes, it was reasonable for them to enter the room, given the information about the drug deal and the dead body. The fact that the other two officers had not waited long before entering the room and frisking Champagne (while Beaudoin was questioned and frisked outside) need not be addressed in these circumstances. Under the inevitable discovery doctrine, the officers would inevitably have entered the room and frisked Champagne once the results of frisking Beaudoin were known. And, inevitably, they would have arrested him, once they found what was in his pockets. See United States v. Scott, 270 F.3d 30, 42 (1st Cir.2001). This is what the district court concluded and we agree. Had Beaudoin not had drugs and a weapon on him, this court would be faced with a much different question about the police entry into the room. One essential purpose of the Fourth Amendment is to impose a standard of reasonableness on the exercise of discretion by the police in order to safeguard “the privacy and security of individuals against arbitrary invasions.” Delaware v. Prouse, 440 U.S. 648, 653-54, 99 S.Ct. 1391, 59 L.Ed.2d 660 (1979) (internal quotation marks omitted). This is distinctly not a case in which the raw question is presented of whether police may barge into someone’s home or even motel room merely based on the receipt of a tip that there is a dead body inside. The concerns raised by such a scenario are very serious. Anonymous tips, without more, do not justify free-wheeling police action. J.L., 529 U.S. at 270, 120 S.Ct. 1375. It is easy for someone to make an anonymous 911 call to the police with a false report of a dead body in a room in order to set up the people in that room. This case shows exactly that: Beaudoin and Champagne were set up by the anonymous tipster. Equally, though, society expects police to investigate reports of dead bodies, and to do so promptly. The reportedly “dead” body might yet be alive and prompt action could save the person. See Wayne, 318 F.2d at 212 (“Acting in response to reports of 'dead bodies,’ the police may find the ‘bodies’ to be common drunks, diabetics in shock, or distressed cardiac patients.... Even the apparently dead often are saved by swift police response.”). Fourth Amendment analysis is re-nownedly fact specific; a step-by-step analysis is inherent in the claim. Defendants, ably represented by counsel, argue that the court should not do a step-by-step analysis of the officers’ actions, but should back up and instead take a look at the entire picture. Courts must do both. There may indeed be rare cases where the entire picture reveals that the reasonableness of each succeeding step was so marginal that an overall conclusion of unreasonableness is warranted. Still, defendants’ disavowal of a step-by-step approach relies too much on doctrinal categories, and not enough on the facts of the case. The Supreme Court expressly disapproved of such an approach in Banks, 124 S.Ct. at 528. We emphatically do not create an anonymously reported murder scene exception to the warrant requirement, nor do we adopt a broad emergency aid doctrine, as defendants fear. There are valid concerns about the harm to Fourth Amendment interests from a generous interpretation of the emergency doctrine as an exception to the warrant requirement. This case does not, in the end, turn on the emergency doctrine alone but turns also on the exigent circumstance of risk to the officers, a risk that justified telling Beaudoin to step out of the doorway and is a justification for the Terry doctrine. From that, all else followed. B. Sentencing Issue Champagne appeals the district court’s two-point increase in his offense level for possession of a dangerous weapon. He contends that it was clearly implausible that the circular saw found in the motel room could have been used as a weapon because it was unwieldy and had to be plugged in to be operational. The district court judge was required to impose the enhancement if the defendant possessed a dangerous weapon “unless it [was] clearly improbable that the weapon was connected with the offense.” U.S.S.G § 2Dl.l(b)(l), cmt. n. 3 (2003). Our review is only for clear error. United States v. Picanso, 333 F.3d 21, 25 (1st Cir.2003). Champagne’s arguments do not demonstrate clear error. The safety cover of the saw was duct-taped so the saw’s blade could be engaged more easily. And the incongruous presence of the saw in a motel room must be considered in conjunction with the fact that Champagne, as a convicted felon, knew that he could not lawfully possess a weapon. Under these circumstances, the district court did not commit clear error in applying the sentencing enhancement for possession of a dangerous weapon. IY. Conclusion The denials of the defendants’ motions to suppress are affirmed. Champagne’s sentence is affirmed. . A few courts have imported an ''intent” requirement, demanding that the officers not be primarily motivated by an intent to arrest and seize evidence. Subsequent Supreme Court case law, we think, eliminates any such intent requirement in favor of a purely objective test. Whren v. United States, 517 U.S. 806, 813, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996); Scott v. United States, 436 U.S. 128, 137, 98 S.Ct. 1717, 56 L.Ed.2d 168 (1978); see United States v. Richardson, 208 F.3d 626, 630 (7th Cir.2000). . Several courts have found that Terry does not justify intrusions into the home. See LaLonde v. Riverside, 204 F.3d 947, 954 (9th Cir.2000); United States v. Winsor, 846 F.2d 1569, 1577-78 (9th Cir.1988) (en banc). But this issue is not before us — the issue, as described below, does not arise from an intrusion into the home or motel room. . The motel was familiar to the police; they had been called there before in criminal matters. Drug deals in Maine motel rooms have certainly happened before. See, e.g., United States v. Julien, 318 F.3d 316, 318 (1st Cir.2003). . This is not, then, an issue of a search inside of a person’s home or motel room or of the arrest of a person in a doorway. Indeed, even in the situation of arrests pursuant to warrant in the doorways of homes, the law is not clearly defined. In the context of doorway arrests, a more serious intrusion than here, this court has noted ”[t]he Supreme Court cases, with Steagald at one pole and Santana at the other, do not definitively resolve [the issue]. Even a quick review of lower court cases reveals that there is no settled answer as to the constitutionality of doorway arrests.” Joyce v. Town of Tewksbury, 112 F.3d 19, 22 (1st Cir.1997). . Consider, for example, if Beaudoin had already left the doorway and the officer simply instructed Beaudoin to step closer to him.
LIPEZ, Circuit Judge, dissenting. The majority concludes that the Hook-sett police officers did not violate the Fourth Amendment’s protections for a private residence when they directed Rodger Beaudoin to step outside of his motel room. In reaching this result, the majority does not rely on the emergency exception doctrine, which provided the basis for the district court’s decision, nor does it accept the government’s alternative argument that the seizure of Rodger Beaudoin was equivalent to an on-the-beat, non-residential Terry-stop to which the Fourth Amendment’s warrant requirement does not apply. Rather, the majority adopts a novel amalgam of Fourth Amendment doctrines that combines the emergency exception doctrine, the traditional exigent circumstance of risk to the safety of police officers, and the Terry doctrine to uphold the officers’ actions under the Fourth Amendment. Absent from this analysis is any consideration of whether the command to Beaudoin was supported by probable cause to believe that a criminal offense had been or was being committed, or probable cause to believe that an individual’s life or safety was in danger within the defendants’ motel room. Because I believe that the majority’s approach is irreconcilable with long-established Fourth Amendment jurisprudence, I respectfully dissent. As I will explain more fully below, under Payton v. New York, 445 U.S. 573, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980), and its progeny, the Fourth Amendment prohibits searches and seizures inside a private residence unless they are conducted pursuant to a warrant or are supported by exigent circumstances and probable cause (or, in the emergency context, by exigent circumstances amounting to probable cause). The Terry doctrine, which permits minimally-intrusive, warrantless stops based on reasonable suspicion of unlawful activity, does not apply to residential searches and seizures. Moreover, for Fourth Amendment purposes, an overnight guest temporarily residing in a hotel or motel room is accorded the same protections as a person residing in his private residence. In my view, the police officers’ order to Beaudoin constituted a seizure of his person from his private residence that implicated Payton’s heightened protections for the home. That seizure was not supported by probable cause of criminal activity or probable cause of a danger to the life or safety of an individual within the defendants’ motel room. Therefore, I would vacate the district court’s order denying the defendants’ motion to suppress. I. Fourth Amendment Requirements for Residential Searches and Seizures The Fourth Amendment’s protections hold particular importance for searches and seizures within a private residence. In Payton v. New York, the Supreme Court explained that: The Fourth Amendment protects the individual’s privacy in a variety of settings. In none is the zone of privacy more clearly defined than when bounded by the unambiguous physical dimensions of an individual’s home — a zone that finds its roots in clear and specific constitutional terms.... In terms that apply equally to seizures of property and seizures of persons, the Fourth Amendment has drawn a firm line at the entrance to the house. 445 U.S. at 589-90, 100 S.Ct. 1371 (emphasis added). The Fourth Amendment’s warrant requirement serves as the primary safeguard against unlawful searches and seizures within the home. Welsh v. Wisconsin, 466 U.S. 740, 748, 104 S.Ct. 2091, 80 L.Ed.2d 732 (1984) (noting that “the physical entry of the home is the chief evil against which the wording of the Fourth Amendment is directed”). These heightened Fourth Amendment protections for the home unmistakably apply to seizures of individuals who reside in hotel or motel rooms as overnight guests. Stoner v. California, 376 U.S. 483, 490, 84 S.Ct. 889, 11 L.Ed.2d 856 (1964) (“No less than a tenant of a house, or the occupant of a room in a boarding house, a guest in a hotel room is entitled to constitutional protection against unreasonable searches and seizures.”)(niternal citation omitted); United States v. Baldacchino, 762 F.2d 170, 175-76 (1st Cir.1985) (defendant “had the same right of privacy [against a war-rantless forced entry into his motel room] that one would have against an intrusion into one’s private dwelling”). Thus, when Beaudoin partially opened the door to his motel room in response to a police knock and request, he was entitled to no less constitutional protection against unreasonable searches and seizures than if he had opened the door to his private residence. A warrantless search of a residence violates the Fourth Amendment’s proscription against unreasonable searches and seizures “unless the search comes within one of a ‘few specifically established and well-delineated exceptions’ ” to the Fourth Amendment’s warrant requirement. United States v. Luciano, 329 F.3d 1, 7 (1st Cir.2003) (quoting Schneckloth v. Bustamonte, 412 U.S. 218, 219, 93 S.Ct. 2041, 36 L.Ed.2d 854 (1973) (quoting Katz v. United States, 389 U.S. 347, 357, 88 S.Ct. 507, 19 L.Ed.2d 576 (1967))). In the context of a residential search or seizure, these specifically established exceptions consist of either consent, or exigent circumstances and probable cause. As the Supreme Court has recently reaffirmed, “police officers need either a warrant or probable cause plus exigent circumstances in order to make a lawful entry into the home.” Kirk v. Louisiana, 536 U.S. 635, 638, 122 S.Ct. 2458, 153 L.Ed.2d 599 (2002); see also Arizona v. Hicks, 480 U.S. 321, 328, 107 S.Ct. 1149, 94 L.Ed.2d 347 (1987) (“A dwelling-place search, no less than a dwelling-place seizure, requires probable cause.”); United States v. Khounsavanh, 113 F.3d 279, 283 (1st Cir.1997) (“While the warrant requirement [for a residential search or seizure] may be dispensed with in certain exigent circumstances that are few in number and carefully delineated, the probable cause requirement is rigorously adhered to.”) (internal citation and quotation marks omitted). Exigent circumstances exist where law enforcement officers confront “a compelling necessity for immediate action that would not brook the delay of obtaining a warrant.” United States v. Tibolt, 72 F.3d 965, 969 (1st Cir.1995). Probable cause requires that “the officers at the scene collectively possess[ ] reasonably trustworthy information sufficient to warrant a prudent policeman in believing that a criminal offense had been or was being committed.” Id. Under a traditional Fourth Amendment analysis, the lawfulness of the Hooksett police officers’ search and seizure of the motel room and of the defendants turns on the initial question of whether Beaudoin exited the motel room voluntarily or whether he did so only in response to a police order. This question is important because a police order to exit your private residence is tantamount to a police seizure of your person within that residence. As the Supreme Court has explained, a person has been seized for Fourth Amendment purposes if “in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave.” United States v. Mendenhall, 446 U.S. 544, 554, 100 S.Ct. 1870, 64 L.Ed.2d 497 (1980). If a reasonable person in Beaudoin’s position would have believed that he was not free to remain inside the motel room because of the force of the police order and apparent authority, then the police constructively entered Beaudoin’s room to effect a seizure within the meaning of the Fourth Amendment. See United States v. Saari, 272 F.3d 804, 809 (6th Cir.2001) (police officers’ conduct constituted a constructive entry where they “summoned Defendant to exit his home and acted with such a show of authority that Defendant reasonably believed he had no choice but to comply”). On the other hand, if a reasonable person in Beaudoin’s position would have believed that he was free to decline to exit the motel room, the directive was not a seizure and did not implicate the Fourth Amendment’s proscription against unreasonable searches and seizures. Although the district court did not explicitly decide whether Beaudoin voluntarily stepped outside of the room, it described the evidence on this point as “equivocal” in its written decision and noted that it was “by no means clear that Beaudoin voluntarily exited the room.” It further noted, at the suppression hearing, that “Mr. Beaudoin was not free under those circumstances to shut the door and decline to come out of the hotel. He was coming out of the hotel whether he wanted to or not.” The government always bears the burden of proving the existence of an exception to the Fourth Amendment’s warrant requirement. United States v. Jeffers, 342 U.S. 48, 51, 72 S.Ct. 93, 96 L.Ed. 59 (1951). Where a warrantless search or seizure is purportedly justified by the defendant’s consent, “the prosecution [must] show, by a preponderance of the evidence, that the consent was knowingly, intelligently, and voluntarily given.” United States v. Marshall, 348 F.3d 281, 285-86 (1st Cir.2003). Given the sharp discrepancy between the two officers’ testimonies, I would read the district court’s observations as a finding that the government failed to establish by a preponderance of the evidence that Beaudoin freely and voluntarily consented to step outside of the motel room. Indeed, the conflicting testimony of the officers would seem to preclude any finding that the government met its burden of proof on its claim that Beaudoin exited the motel room voluntarily. Therefore, I would conclude that the police officers’ order to Beaudoin to step outside constituted a seizure of his person from his motel room. Whether Payton’s heightened protections for the home apply in this case depends not only upon whether the order to Beaudoin constituted a seizure but also upon whether it was a residential seizure. While one can argue in some cases about where the entrance to a private residence begins, the Fourth Amendment’s warrant requirement and protections for the home are either implicated by a given search or seizure or they are not. In Kyllo v. United States, 533 U.S. 27, 30, 121 S.Ct. 2038, 150 L.Ed.2d 94 (2001), the Supreme Court reaffirmed Payton, explaining that: “We have said that the Fourth Amendment draws ‘a firm line at the entrance to the house.’ That line, we think, must be not only firm but also bright.” On the external, public side of Payton’s firm line, a police officer’s conduct is not subject to Payton’s protections. On the internal, residential side of this line, police officers must obtain a warrant supported by probable cause prior to conducting a non-consensual search or seizure, or demonstrate that their actions are justified by exigent circumstances and probable cause. The important question in this case, therefore, is not whether the police conduct was intrusive, non-intrusive, or something in between when weighed against Beaudoin’s reasonable expectation of privacy, but whether the Fourth Amendment’s warrant requirement and heightened protections for the home were implicated by the challenged police conduct. If the police officers’ seizure of Beaudoin had taken place outside of the motel room, the Fourth Amendment’s warrant requirement would not apply, and the police officers’ directive to Beau-doin might be understood as the equivalent of a brief, investigative Terry stop, which requires only a “reasonable suspicion of wrongdoing — a suspicion that finds expression in specific, articulable reasons for believing that a person may be connected to the commission of a particular crime” in order to meet the Fourth Amendment’s reasonableness requirement. United States v. Lee, 317 F.3d 26, 31 (1st Cir.2003) (citing Terry v. Ohio, 392 U.S. 1, 20, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968)). The reasonable suspicion standard is “an intermediate standard requiring more than unfounded speculation but less than probable cause.” United States v. Cook, 277 F.3d 82, 85 (1st Cir.2002) (quoting Ornelas v. United States, 517 U.S. 690, 696, 116 S.Ct. 1657, 134 L.Ed.2d 911 (1981)). In evaluating whether a Terry stop was justified by reasonable suspicion, the reviewing court must examine “‘the totality of the circumstances’ of each case to see whether the detaining officer ha[d] a ‘particular and objective basis’ for suspecting legal wrongdoing.” United States v. Arvizu, 534 U.S. 266, 273, 122 S.Ct. 744, 151 L.Ed.2d 740 (2002). In the course of a legitimate Terry stop, a police officer may conduct a frisk of the suspect, searching his or her person for weapons, “on reasonable suspicion that the suspect is armed and dangerous.” United States v. Scott, 270 F.3d 30, 31 (1st Cir.2001), cert. denied 535 U.S. 1007, 122 S.Ct. 1583, 152 L.Ed.2d 501 (2002). In arguing that the seizure of Beaudoin was justified under the Terry doctrine, the government suggested that under the Supreme Court’s decision in United States v. Santana, Beaudoin had no reasonable expectation of privacy in his motel room once he opened the door to the police. See United States v. Santana, 427 U.S. 38, 40 n. 1, 42, 96 S.Ct. 2406, 49 L.Ed.2d 300 (1976) (holding that a suspect “was in a public place” and could be arrested without a warrant where she was standing “directly in the doorway ... not merely visible to the public but [] exposed to public view, speech, hearing, and touch, as if she had been standing completely outside of her house”). The government relied on the Second Circuit’s opinion in United States v. Gori, which found that the Santana doorway exception permitted a Terry-type investigatory stop based on reasonable suspicion where defendants voluntarily opened the door of their apartment to public view in response to the knock of a delivery person they had invited. 230 F.3d 44, 53 (2d Cir.2000); c.f. Saari, 272 F.3d at 811 (finding that Terry did not apply where the defendant was forcibly summoned out of the house at the command of the police and did not voluntarily relinquish Payton’s heightened protections for the home). In my view, the Santana doorway exception does not obviate the need in this case for a warrant or exigent circumstances plus probable cause. Unlike the defendants in Gori, who “opened [then-apartment] to public view ... in response to the knock of an invitee” and therefore had “no expectation of privacy as to what could be seen from the hall,” Beaudoin opened the interior door of his motel room in response to a knock and request by law enforcement officials. Moreover, he opened the door just enough to reveal his face, exposing nothing inside the room. He did not relinquish his and Robert Champagne’s reasonable expectation of residential privacy. Thus, when the police ordered Beaudoin to step outside, he was not in a place where Terry’s reasonable suspicion analysis would apply in lieu of the probable cause basis required for a search or seizure within a private residence. Because Beaudoin did not voluntarily step outside of the motel room or voluntarily expose the room to public view, Payton’s heightened protections for private residences apply in this case. II. Fourth Amendment Doctrines and the Majority’s Exigency/Emergency/ Terry Approach As noted above, the majority does not uphold the warrantless seizure of Beau-doin based on the presence of exigent circumstances plus probable cause nor does it affirm the district court’s denial of the motion to suppress under the emergency exception doctrine. It also does not adopt the alternative argument advanced below by the government that the order to Beau-doin did not take place within Beaudoin’s private residence and thus constituted a Terry stop that was justified solely on the ground of reasonable suspicion of unlawful activity. Instead, the majority’s analysis “involves the intersection of several Fourth Amendment doctrines, most notably, those of exigent circumstances, emergencies, and Terry-type temporary detentions during investigation.” Under this analysis, “the issue is whether the command [to Beaudoin] was justified under the combination of the three doctrines.” This combination of Fourth Amendment doctrines is an innovation. To my knowledge, no other court has combined the traditional exigent circumstances doctrine, the emergency exception doctrine, and the Terry doctrine to justify a residential search or seizure. The outcome of this unusual mix is an analysis that is, in my view, at odds with each of the doctrines it purports to adopt. A. The Terry Doctrine The majority’s emergency/exigency/ Terry approach removes the Terry doctrine from its constitutional moorings and extends the doctrine to the seizure of a person from his private residence. First, the majority suggests that the Terry doctrine applies to the police officers’ order to Beaudoin because Beaudoin stopped voluntarily when he opened the curtain to his motel room and answered the knock at his door. Thus, the majority claims that the circumstances that culminated in the order to Beaudoin to exit his motel room were like “a situation in which a person voluntarily stops, and then the police take reasonable steps, during that temporary stop to protect themselves during the questioning.” Although the majority is correct that once a Tern/ stop has occurred, “an officer may search a person for weapons based on reasonable suspicion that a person is armed and dangerous,” the voluntary actions that the majority describes do not constitute the involuntary, investigative Terry stop (the seizure) that is the premise of the Terry analysis. Indeed, the so-called voluntary “stop” of Beaudoin within the motel room seems to be offered as a substitute for the involuntary Terry seizure, which would require reasonable suspicion that Beaudoin had committed, was committing, or was about to commit a crime. More importantly, the majority’s analysis overlooks the critical fact that Beaudoin was inside his motel room when he looked out the window and responded to the officers’ knock by opening the door to his motel room just far enough to reveal his face. This situation differs in constitutionally significant ways from a situation in which police officers conduct a voluntary stop of an individual in a public setting. In order to place Beaudoin in a situation where Terry’s reasonable suspicion standard might apply, the officers had to order him to exit his room. Terry did not justify that command because Terry does not apply to seizures of individuals from their private residences. Although the majority observes that “[wjhen the officer suspects a crime of violence, the same information that will support an investigatory stop will without more support a protective search,” it is the stop, not the protective search, that is at issue in this case. The majority’s blend of Fourth Amendment doctrines overlooks the importance of place in determining whether a minimally intrusive seizure can be justified under Terry’s reasonable suspicion standard. The majority cautions that this case does not present “any abstract issue ... about the application of Terry to persons in doorways absent the emergency and exigent circumstances present here.” Yet Terry’s applicability to the order to Beaudoin does not turn on the presence or absence of exigent circumstances but on the physical location of Beaudoin and the police officers at the time of the seizure. Terry itself distinguished police conduct “predicated upon the on-the-spot observations of an officer on the beat — which historically has not been and as a practical matter could not be, subject to the warrant procedure” from “conduct subject to the Warrant Clause of the Fourth Amendment.” Terry, 392 U.S. at 20, 88 S.Ct. 1868. Terry dealt with the former category of conduct and did not require exigent circumstances or probable cause to justify the warrantless seizure — because a warrant was not required in the first place. By contrast, if the situation in Terry involved conduct subject to the Fourth Amendment’s warrant requirement, the Court “would have [had] to ascertain whether ‘probable cause’ existed to justify the search and seizure which took place.” Id. Thus, the majority’s incorporation of Terry into an exigency/emergency analysis overlooks the constitutional difference between police conduct in the home and police conduct outside it. This approach represents a significant departure from well-established Fourth Amendment doctrine, under which residential seizures must be supported by a warrant or exigent circumstances and probable cause, whereas seizures short of arrest that are conducted outside of the home do not require a warrant and may be justified under Terry’s reasonable suspicion standard. The command to Beaudoin to exit his motel room constituted a seizure of Beaudoin from his private residence. It was an intrusion of significant import that required a search warrant or exigent circumstances plus probable cause. Therefore, Payton, not Terry, applies in this case. B. The Exigent Circumstances and Emergency Doctrines Just as the majority’s approach is inconsistent with the Terry doctrine, so too it cannot be reconciled with the traditional exigent circumstances doctrine or the emergency exception doctrine. 1. The Exigent Circumstances Doctrine Under a traditional Fourth Amendment analysis, exigent circumstances present an exception to the Fourth Amendment’s warrant requirement for residential searches and seizures. Exigent circumstances involve a “compelling necessity for immediate action as w[ould] not brook the delay of obtaining a warrant.” United States v. Wilson, 36 F.3d 205, 209 (1st Cir.1994)(quoting United States v. Adams, 621 F.2d 41, 44 (1980)). The exigent circumstances analysis is necessarily fact-intensive and is “limited to the objective facts reasonably known to, or discoverable by, the officers at the time of the search.” Tibolt, 72 F.3d at 969. As the majority notes, this circuit has recognized that exigent circumstances may exist where a suspect poses a threat “to the lives or safety of the public, the police officers, or to herself.” Hegarty v. Somerset Cty., 53 F.3d 1367, 1375 (1st Cir.1995). Yet exigent circumstances alone cannot excuse the Fourth Amendment’s warrant requirement for residential searches and seizures. While the majority is correct that a risk to the safety of the public or the police may rise to the level of an exigent circumstance, our case law is clear that this exigency justifies a warrantless residential search or seizure only where it is also supported by probable cause. See, e.g., United States v. Bartelho, 71 F.3d 436, 442 (1st Cir.1995); United States v. Lopez, 989 F.2d 24, 27 (1st Cir.1993). Thus, the traditional exigent circumstances doctrine requires two separate elements. The exigent circumstance element focuses on circumstances that are incident to the criminal investigation, such as a risk of flight, the destruction of evidence, or a risk to police officer safety. The probable cause element focuses on the suspicion of criminal activity, which must amount to probable cause to believe that a crime has been or is being committed. In the absence of a valid search warrant or consent, both elements must be present in order to justify a search or seizure within a private residence. 2. The Emergency Exception Doctrine The Supreme Court has recognized that some emergencies may obviate the need to obtain a warrant prior to entering a private residence, Mincey v. Arizona, 437 U.S. 385, 392, 98 S.Ct. 2408, 57 L.Ed.2d 290 (1978), and numerous state and federal courts have upheld emergency entries and searches of private residences based on the need to render emergency aid. See United States v. Holloway, 290 F.3d 1331, 1336-37 (11th Cir.2002) (collecting cases). In contrast to the traditional exigent circumstance case, in which the exigency presents itself in the course of a criminal investigation and requires probable cause of criminal activity, a search or seizure that falls under the emergency exception doctrine may be only incidentally connected to unlawful acts. Police officers responding to emergency situations are responding to the need to locate and provide assistance to a person whose life may hang in the balance rather than the search for evidence of criminal activity. As the Fourth Circuit has explained, “[t]his particular exigency is expressed as one of [a] reasonably perceived ‘emergency’ requiring immediate entry as an incident to the service and protective functions of the police as opposed to, or as a complement to, their law enforcement functions.” United States v. Moss, 963 F.2d 673, 678 (4th Cir.1992). A Fourth Amendment issue arises in these emergency exception cases only when someone becomes the subject of a search or seizure within the protected area, usually because the police discover evidence of criminal activity while searching for the individual believed to be in need of aid. In such cases, the reasonableness of the search or seizure does not depend on the existence of probable cause to believe that criminal activity had been or was being committed. Indeed, the law enforcement officers initially may not be aware of any connection between the emergency and a crime. Instead, the reasonableness of the intrusive action under the emergency doctrine depends on the objective probability that someone’s life or safety is in danger within a setting protected by the Fourth Amendment. Thus, the emergency exception suggested by Mincey, and adopted in various forms by state and federal courts, does not dispense with the Fourth Amendment’s probable cause requirement. In applying the emergency doctrine, other circuits have found that the Fourth Amendment requires a standard of suspicion approximating probable cause to justify a warrantless search or seizure in a private residence under the emergency exception doctrine. While the phrasing of the applicable standard varies, I agree with the Second Circuit that probable cause exists in the emergency context where there exists a probability that an individual’s life or safety is in danger within an area protected by the Fourth Amendment. See Koch v. Town of Brattleboro, 287 F.3d 162, 169 (2d Cir.2002) (probable cause under the emergency doctrine requi