whether Rohrig stands for the proposition that the community-caretaking exception can justify warrantless entries into private residences. See, e.g., Williams, 354 F3d at 508 (“[Djespite references to the doctrine in Rohrig, we doubt that community caretaking will generally justify warrantless entries into private homes.”). 45 Ray v Warren Twp, 626 F3d 170, 177 (CA 3, 2010). 46 See, e.g., Ortiz v State, 24 So 3d 596, 615 (Fla App, 2009) (Orfinger, J., dissenting) (“Other than situations involving the medical emergency exception, until today, the community caretaker exception has not been applied in Florida as a separate exception to the Fourth Amendment to validate an entry into a residence.”). 47 See, e.g., State v Ford, 2010 VT 39, ¶¶ 11-21; 188 Vt 17, 24-29; 998 A2d 684 (2010) (<HOLDING>). 48 United States v Quezada, 448 F3d 1005 (CA
holding that in every warrantless entry into private residence state has burden to demonstrate that exigencies of situation made entry imperative recognizing the rule and the exception but holding facts did not support claim to exception recognizing exception recognizing the existence of both the communitycaretaking and emergencyaid exceptions but holding an officers entry into a private residence unconstitutional because it failed to satisfy the emergencyaid exception recognizing an exception to a california announcement and entry statute