evidence and maintaining safety may not outweigh individual privacy interests intruded upon by a no-knock entry.” Richards v. Wisconsin, 520 U.S. 385, 393, 117 S.Ct. 1416, 137 L.Ed.2d 615 (1997). We have previously indicated a particularized basis was not demonstrated when officers failed to demonstrate the suspects’ ability to destroy the evidence. Van Beek, 1999 ND 53, ¶ 18, 591 N.W.2d 112. In Van Beek, we noted that, when drugs are kept in a garage, the proposition drugs will be destroyed is even more doubtful. Id. [¶20] The search warrant was issued for Utviek’s hotel room. The layout of a hotel room may have made it particularly easy for a suspect to destroy evidence, given the probable location of the bathroom. See Michigan v. Hall, 1999 Mich. App. LEXIS 651, 4 unpublished (<HOLDING>); see also Wisconsin v. Henderson, 245 Wis.2d
holding exigent circumstances existed because bathroom in hotel room was next to hallway door where the narcotics could have been particularly flushed and the suspected drug was crackcocaine which makes it not impossible that drugs were easily disposable holding that a visitor to a hotel room for purposes of distributing drugs failed to establish a reasonable expectation of privacy in the room holding exigent circumstances demonstrated because officers knew defendant stored drugs in room across from the bathroom making destruction particularly easy holding exigent circumstances found because detailed affidavit alleged drug transactions were conducted near the bathroom for quick disposal of the evidence holding that in narcotics cases the need to invoke the exigent circumstances exception to the warrant requirement is particularly compelling in narcotics eases because narcotics can be so quickly destroyed quoting united states v young 909 f2d 442 446 11th cir1990