An example of this can be found in the case Bennet v. Commonwealth, where evidence obtained was found to be unconstitutional (1972). According to Washington and Lee Law Review, "All warrantless searches are unreasonable unless they are conducted by consent or are incident to a lawful arrest" (1973, pg.133). To reiterate, only by consent or by exigent circumstances can arson investigators search without a warrant (pg.136). The fact patterns of Bennet v. Commonwealth, and the actions of the fire marshals who investigated the origin of the fire did not "procure a warrant" for criminal probable cause (1973). Furthermore, "the search in that case was authorized by the State Corporation Commission and Fire Hazards Law" upon the basis of an administrative
