Ruiz-Ravelo v. United States

How later courts describe this case

• ruling that exigent circumstances existed where the subject of an arrest warrant “had previously expressed his willingness to use firearms against police”
• upholding search incident to arrest even though, as a safety precaution, suspect was handcuffed and removed from room prior to search
• failure to place affiant under oath until after she had recited supporting facts for search warrant did not invalidate telephonic warrant