Is the Exigent Circumstances Doctrine an Exception to the Warrant Requirement, or Something More?

I have long thought of the exigent circumstances doctrine as an exception to the warrant requirement – it allows a search to be conducted when probable cause is present but it is impractical for officers to take the time to obtain a search warrant. That understanding was shaken when I read Phil Dixon’s summary of United States v. Curry, 937 F.3d 363 (4th Cir. 2019). The majority in Curry ruled that exigent circumstances allowed officers to search several men without probable cause or even reasonable suspicion because they were walking away from an area where shots had just been fired. In other words, the court took the position that exigent circumstances excused not only the lack of a warrant, but also the lack of individualized suspicion. Have I been mistaken all these years? The facts of Curry. Officers in Richmond, Virginia were patrolling a residential area that was the “site of frequent gun violence.” They “heard several gunshots close by” and drove in the direction of the shots, arriving less than a minute later. They encountered a number of people, some remaining in the area and others, including a half-dozen men, not necessarily together, walking away. Although the officers had no specific reason to believe that any of the men had been involved in the shooting, the proximity in time and place to the gunshots led the officers to “shine[] flashlights on the men and instruct[] them to stop, raise their hands, and then lift their shirts to expose their waistbands [...]