Following Turrubiate, Texas courts have required proof that the officer conducting a warrantless search due to exigent circumstances based on the potential destruction of evidence believed that the removal or destruction of evidence was imminent. See, e.g., Igboji v. State, 607 S.W.3d 157 (Tex.App.-Houston [14th Dist] Sept. 22, 2020); Meane v. State, 527 S.W.3d 557 (Tex.App.-Houston [1st Dist] June 29, 2017); Lasyone v. State, 2014 WL 3662567 (Tex.App.-Tyler July 23, 2014).
As a general rule, a search is unreasonable if it is conducted without a valid warrant. See Meane v. State, 527 S.W.3d 557, 560 (Tex. App.—Houston [1st Dist.] 2017, no pet.). However, it is well-established that a warrant is not required if the person being searched gives consent.