(Cf. In re Quackenbush (1996) 41 Cal.App.4th 1301, 1306-1307 [ 49 Cal.Rptr.2d 147] [where dog has bitten someone, exigent circumstances may justify warrantless seizure of dog from residence if necessary to determine whether dog has rabies]; see also Camara v. Municipal Court (1967) 387 U.S. 523 [ 18 L.Ed.2d 930, 87 S.Ct. 1727] [ Fourth Amendment precludes warrantless searches of residence to enforce municipal fire, health, and housing codes].) On the contrary, the police indicated that Toby was lying on the bed, that he was not disruptive, and that he had done nothing improper inside the house.

( Id. at p. 175.) Likewise, there was no exigency in In re Quackenbush (1996) 41 Cal.App.4th 1301 [ 49 Cal.Rptr.2d 147]. Quackenbush involved the warrantless seizure of a dog that had bitten someone two days earlier.

( Id. at p. 175.) Likewise, there was no exigency in In re Quackenbush (1996) 41 Cal.App.4th 1301 [ 49 Cal.Rptr.2d 147]. Quackenbush involved the seizure of a dog that had bitten someone two days earlier.

For example, in Conway v. Pasadena Humane Soc'y, 45 Cal. App. 4th 163, 176 (1996), the court concluded that the Fourth Amended protected homeowners from a warrantless search of their home and seizure of their dog. Likewise in In re Quackenbush, 41 Cal. App. 4th 1301, 1308 (1996), as modified on denial of reh'g (Feb. 13, 1996), the court concluded that the Fourth Amendment protected against the warrantless seizure of a dog because that seizure meaningfully interfered with the plaintiff's possessory interests in the dog. See also Jackson v. Silicon Valley Animal Control Auth., No. C 07-5667 RS, 2008 WL 4544455 (N.D. Cal. Oct. 2, 2008) (concluding that exigent circumstances exception extended to warrantless entry to search and seize animals).