NEHRING, Justice:
T1 The issue presented in this case is whether the detectable odor of burning mariJuana creates an exigent cireumstance permitting a warrantless search of a residence. We hold that it does not.
BACKGROUND
2 This case presents a purely legal issue. Our recounting of the facts is therefore spare. On April 22, 2003, the brother and the mother of Lance Horvath called police officers to report that people were smoking marijuana inside Mr. Horvath's trailer, which was located on his mother's property. When officers arrived about forty minutes later, the brother reported that he had personally observed people in the trailer smoking marijuana and warned that, although Mr. Horvath was away at the time, he kept guns in his trailer and had threatened to use them against the police.
13 The police officers later testified that as they approached the trailer, they could smell the faint but unmistakable odor of "marijuana leakin' out of the cracks of the trailer." Concluding that time was of the essence because the occupants were "in the very process of smokin' up the evidence," the officers entered the trailer without first obtaining a warrant. Inside the trailer, the officers found controlled substances, several [797]*797firearms, and three individuals, including the defendant, Bernadette Duran.
T4 At trial, the court denied Ms. Duran's motion to suppress the evidence found in the warrantless search. The court of appeals reversed, holding that although the odor of marijuana to which the officers testified gave rise to probable cause for a search, it did not create exigent cireumstances that would justify their warrantless search of the trailer. State v. Duran, 2005 UT App 409, ¶ 23, 131 P.3d 246.
ANALYSIS
T5 On certiorari, we review the decision of the court of appeals, not that of the trial court. State v. Krukowski, 2004 UT 94, ¶ 10, 100 P.3d 1222. The issue of whether a warrantless search of a residence is reasonable under the Fourth Amendment is a question of law, which we review for correctness. See State v. Peterson, 2005 UT 17, ¶ 8, 110 P.3d 699.
16 We decline to grant the aroma of burning marijuana a place on an exclusive, limited roster of exceptions to the requirement that a warrant be secured before a lawful search can occur. The Fourth Amendment to the United States Constitution guarantees "[the right of the people to be secure in their ... houses ... against unreasonable searches and seizures." As the TUnited States Supreme Court has stated, "physical entry of the home is the chief evil against which the wording of the Fourth Amendment is directed." United States v. U.S. Dist. Court, 407 U.S. 297, 313, 92 S.Ct. 2125, 32 L.Ed.2d 752 (1972). Accordingly, "searches and seizures inside a home without a warrant are presumptively unreasonable," even when officers have probable cause to search. Payton v. New York, 445 U.S. 573, 586, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980).
{7 The Supreme Court has recognized, however, a few narrow exceptions to this warrant requirement. Under the exigent cireumstances exception, officers may search a residence without a warrant where a "specially pressing or urgent law enforcement need," Illinois v. McArthur, 531 U.S. 326, 331, 121 S.Ct. 946, 148 L.Ed.2d 838 (2001), makes "the warrantless search ... objectively reasonable under the Fourth Amendment," Mincey v. Arizona, 437 U.S. 385, 394, 98 S.Ct. 2408, 57 L.Ed.2d 290 (1978). The Court has identified prevention of the "imminent destruction of evidence" as one such pressing need. Minnesote v. Olson, 495 U.S. 91, 100, 110 S.Ct. 1684, 109 L.Ed.2d 85 (1990).
18 We, too, have "sustained war-rantless entries where the circumstances indicated that evidence might be destroyed or removed if entry was delayed until a warrant could be obtained." State v. Ashe, 745 P.2d 1255, 1258 (Utah 1987). To be clear, this does not include "the mere possibility that evidence may be destroyed." State v. South, 885 P.2d 795, 800 (Utah Ct.App.1994), rev'd on other grounds, 924 P.2d 354 (Utah 1996). Rather, police officers must have a reasonable belief that the destruction of evidence is sufficiently certain as to justify a warrantless entry based on exigent cireumstances. We find, however, that the detectable odor of burning marijuana is inadequate, standing alone, to support such a reasonable belief. The aroma of burning marijuana must be accompanied by some evidence that the suspects are disposing of the evidence, as opposed to casually consuming it, before law enforcement officials may be lawfully justified in claiming the benefit of the exigent cireumstances exception.
T9 We decline to pare back a fundamental constitutional guarantee where the commission of an offense-in this case, smoking marijuana-involves as its incidental but inevitable consequence the destruction of evidence. According to the testimony of the police officers who conducted the warrantless entry in this case, the marijuana was being "destroyed" by persons who were "in the very process of smokin' up the evidence." This is an odd departure, indeed, from the cireumstances that typically attend destruction of evidence exigencies. In most instances, an exigency arises from the possibility that persons, alerted to the presence of law enforcement officials seeking to execute a search warrant, might understandably rid themselves of any trace of contraband. See United States v. Tobin, 923 F.2d 1506, 1511 [798]*798(11th Cir.1991) (en bane) (holding that exigent cireumstances were present where "the [law enforcement] agents could reasonably conclude from the defendants' hurried actions and furtive looks that [they] were either aware or afraid that someone was watching them [and][dlestruction or removal of ... the narcotics was therefore a possibility" (footnote omitted)). The reverse is also true, as it is well-recognized that "[clireumstances are not normally considered exigent where the suspects are unaware of police surveillance." Id. at 1511; see, e.g., United States v. Elkins, 300 F.3d 638, 656-57 (6th Cir.2002); United States v. Davis, 170 F.Supp.2d 1234, 1239 (M.D.Fla.2001).
110 A person bent on destroying contraband may well turn to ingesting it to avoid its detection. See State v. Alverez, 2006 UT 61, 147 P.3d 425. It is nevertheless unlikely that a person in possession of contraband, like marijuana, would be so consumed by paranoia as to dispose of the contraband by ingestion, having no reason to suspect that law enforcement might be alerted to the illegal activities.
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NEHRING, Justice:
T1 The issue presented in this case is whether the detectable odor of burning mariJuana creates an exigent cireumstance permitting a warrantless search of a residence. We hold that it does not.
BACKGROUND
2 This case presents a purely legal issue. Our recounting of the facts is therefore spare. On April 22, 2003, the brother and the mother of Lance Horvath called police officers to report that people were smoking marijuana inside Mr. Horvath's trailer, which was located on his mother's property. When officers arrived about forty minutes later, the brother reported that he had personally observed people in the trailer smoking marijuana and warned that, although Mr. Horvath was away at the time, he kept guns in his trailer and had threatened to use them against the police.
13 The police officers later testified that as they approached the trailer, they could smell the faint but unmistakable odor of "marijuana leakin' out of the cracks of the trailer." Concluding that time was of the essence because the occupants were "in the very process of smokin' up the evidence," the officers entered the trailer without first obtaining a warrant. Inside the trailer, the officers found controlled substances, several [797]*797firearms, and three individuals, including the defendant, Bernadette Duran.
T4 At trial, the court denied Ms. Duran's motion to suppress the evidence found in the warrantless search. The court of appeals reversed, holding that although the odor of marijuana to which the officers testified gave rise to probable cause for a search, it did not create exigent cireumstances that would justify their warrantless search of the trailer. State v. Duran, 2005 UT App 409, ¶ 23, 131 P.3d 246.
ANALYSIS
T5 On certiorari, we review the decision of the court of appeals, not that of the trial court. State v. Krukowski, 2004 UT 94, ¶ 10, 100 P.3d 1222. The issue of whether a warrantless search of a residence is reasonable under the Fourth Amendment is a question of law, which we review for correctness. See State v. Peterson, 2005 UT 17, ¶ 8, 110 P.3d 699.
16 We decline to grant the aroma of burning marijuana a place on an exclusive, limited roster of exceptions to the requirement that a warrant be secured before a lawful search can occur. The Fourth Amendment to the United States Constitution guarantees "[the right of the people to be secure in their ... houses ... against unreasonable searches and seizures." As the TUnited States Supreme Court has stated, "physical entry of the home is the chief evil against which the wording of the Fourth Amendment is directed." United States v. U.S. Dist. Court, 407 U.S. 297, 313, 92 S.Ct. 2125, 32 L.Ed.2d 752 (1972). Accordingly, "searches and seizures inside a home without a warrant are presumptively unreasonable," even when officers have probable cause to search. Payton v. New York, 445 U.S. 573, 586, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980).
{7 The Supreme Court has recognized, however, a few narrow exceptions to this warrant requirement. Under the exigent cireumstances exception, officers may search a residence without a warrant where a "specially pressing or urgent law enforcement need," Illinois v. McArthur, 531 U.S. 326, 331, 121 S.Ct. 946, 148 L.Ed.2d 838 (2001), makes "the warrantless search ... objectively reasonable under the Fourth Amendment," Mincey v. Arizona, 437 U.S. 385, 394, 98 S.Ct. 2408, 57 L.Ed.2d 290 (1978). The Court has identified prevention of the "imminent destruction of evidence" as one such pressing need. Minnesote v. Olson, 495 U.S. 91, 100, 110 S.Ct. 1684, 109 L.Ed.2d 85 (1990).
18 We, too, have "sustained war-rantless entries where the circumstances indicated that evidence might be destroyed or removed if entry was delayed until a warrant could be obtained." State v. Ashe, 745 P.2d 1255, 1258 (Utah 1987). To be clear, this does not include "the mere possibility that evidence may be destroyed." State v. South, 885 P.2d 795, 800 (Utah Ct.App.1994), rev'd on other grounds, 924 P.2d 354 (Utah 1996). Rather, police officers must have a reasonable belief that the destruction of evidence is sufficiently certain as to justify a warrantless entry based on exigent cireumstances. We find, however, that the detectable odor of burning marijuana is inadequate, standing alone, to support such a reasonable belief. The aroma of burning marijuana must be accompanied by some evidence that the suspects are disposing of the evidence, as opposed to casually consuming it, before law enforcement officials may be lawfully justified in claiming the benefit of the exigent cireumstances exception.
T9 We decline to pare back a fundamental constitutional guarantee where the commission of an offense-in this case, smoking marijuana-involves as its incidental but inevitable consequence the destruction of evidence. According to the testimony of the police officers who conducted the warrantless entry in this case, the marijuana was being "destroyed" by persons who were "in the very process of smokin' up the evidence." This is an odd departure, indeed, from the cireumstances that typically attend destruction of evidence exigencies. In most instances, an exigency arises from the possibility that persons, alerted to the presence of law enforcement officials seeking to execute a search warrant, might understandably rid themselves of any trace of contraband. See United States v. Tobin, 923 F.2d 1506, 1511 [798]*798(11th Cir.1991) (en bane) (holding that exigent cireumstances were present where "the [law enforcement] agents could reasonably conclude from the defendants' hurried actions and furtive looks that [they] were either aware or afraid that someone was watching them [and][dlestruction or removal of ... the narcotics was therefore a possibility" (footnote omitted)). The reverse is also true, as it is well-recognized that "[clireumstances are not normally considered exigent where the suspects are unaware of police surveillance." Id. at 1511; see, e.g., United States v. Elkins, 300 F.3d 638, 656-57 (6th Cir.2002); United States v. Davis, 170 F.Supp.2d 1234, 1239 (M.D.Fla.2001).
110 A person bent on destroying contraband may well turn to ingesting it to avoid its detection. See State v. Alverez, 2006 UT 61, 147 P.3d 425. It is nevertheless unlikely that a person in possession of contraband, like marijuana, would be so consumed by paranoia as to dispose of the contraband by ingestion, having no reason to suspect that law enforcement might be alerted to the illegal activities. We are unable, therefore, to identify the existence of an exigency under circumstances that require equating the consumption of contraband with destruction of evidence where the persons affected by the search had no apprehension that law enforcement had them in their sights.
T11 In this case, Ms. Duran made no effort, hurried or otherwise, to dispose of her marijuana in order to prevent its discovery by law enforcement. Until the warrantless entry of law enforcement officers into the trailer, she remained unaware of any police involvement and had no objective reason to "destroy" the marijuana, as that term is commonly understood. In fact, it is likely that no one involved in this episode was more dismayed at the prospect of the destruction of "evidence" than Ms. Duran.
T12 Further, nothing in the record suggests that law enforcement had reason to believe that the evidence of drug use would be destroyed if the officers had delayed their intrusion until they secured a warrant. Because Ms. Duran was unaware of the police presence, it is unlikely that all traces of her drug use would have disappeared from the trailer in the time it took law enforcement to obtain a warrant. Presumably, even if some of the marijuana was destroyed through the process of smoking while law enforcement sought a warrant, some evidence of drug use would linger in the form of residue, smoking paraphernalia, and some quantity of un-smoked marijuana. The officer's statement that Ms. Duran was "smokin' up the evidence" nicely underscores the obvious conclusion that the officers were not confronting the conflagration of the contraband that a reasonable person would associate with the destruction of evidence.
113 We also decline to sanction the war-rantless search in this context because we fear that it would be difficult to leash war-rantless searches in other contexts in which consumption and destruction of evidence merge. It is certainly not far-fetched to envision law enforcement officers exploiting the rationale that consumption of contraband is also evidence destruction to justify war-rantless searches in other contexts. After all, the exigency present here is not appreciably different from a report of consumption of alcohol by underage persons in a dwelling. Like smoking marijuana, underage drinking is a jailable offense crime in which the erimi-nal act involves simultaneous consumption of contraband and destruction of evidence. See Utah Code Ann. §§ 32A-12-104, -209(1) (2005). Also, olfactory-based probable cause could, under a doctrine that equated consumption of contraband with destruction of evidence, permit a law enforcement officer to claim exigent cireumstances to justify a war-rantless search to apprehend eighteen-year-olds believed to be smoking tobacco. See Utah Code Ann. § 76-10-105 (2006) ("Any 18 year old person who buys or attempts to buy, accepts, or has in his possession any cigar, cigarette, or tobacco in any form is guilty of a class C misdemeanor. ...").
1 14 In short, the costs that would accompany a merger of consumption of contraband and destruction of evidence-iLe., an increase in questionable warrantless searches, a corresponding decrease in personal privacy, a decreased incentive for law enforcement to seek a warrant before conducting a search, and a further erosion of Fourth Amendment [799]*799protections-outweigh the benefits accruing to the state in more efficient law enforcement. As a society, we have little to lose and much to gain by insisting that the definition of "imminent destruction of evidence" necessary to create an exigent cireumstance be limited to the common understanding of evidence "destruction"-disposal of, not consumption of, contraband.
{15 Contributing to our confidence that this is the correct conclusion is our belief that we should, as a general proposition, narrowly construe the reach of exceptions to fundamental constitutional rights. This principle is well-suited to this occasion. While it is true that marijuana is destroyed during the process of smoking, we hold that this does not, without more, create an exigent cireum-stance sufficient to justify a warrantless search.
{16 The State looks to Illinois v. McAr-thur to support the proposition that a war-rantless search based on exigent cireum-stances can be justified when the suspected crime giving rise to the search is a "Jailable offense." 531 U.S. 326, 121 S.Ct. 946 (2001). This is correct, but McArthur also supports our position that, although probable cause of marijuana use could justify a warrantless search based on exigent cireumstances, no exigency was present here. In McArthur, the United States Supreme Court held that it was reasonable for law enforcement officers to prevent a man from entering his home while they took the steps necessary to obtain a warrant when they had probable cause to believe that the man had marijuana in his home. Id. at 838, 121 S.Ct. 946. Noting that the Fourth Amendment's " 'central requirement' is one of reasonableness," the MceAr-thur Court "balance[d] the privacy-related and law enforcement-related concerns to determine if the intrusion was reasonable." Id. at 331, 121 S.Ct. 946 (quoting Texas v. Brown, 460 U.S. 730, 739, 108 S.Ct. 1535, 75 LEd.2d 502 (1983)). The Court held that the seizure was reasonable based on four factors: (1) the police had probable cause to believe that there was evidence of "crime and contraband" in the home, i.e., illegal drugs; (2) the police had good cause to believe that the suspect would destroy the evidence before they could obtain a warrant, unless he was restrained; (8) "the police made reasonable efforts to reconcile their law enforcement needs with the demands of personal privacy" by "neither search[ing] the trailer nor arrest[ing the suspect] before obtaining a warrant"; and (4) the police blocked entry to the home for only a limited amount of time-two hours. Id. at 3831-82, 121 S.Ct. 946. Further, the Court explained, "We have found no case in which this Court has held unlawful a temporary seizure that was supported by probable cause and was designed to prevent the loss of evidence while the police diligently obtained a warrant in a reasonable period of time."1 Id. at 334, 121 S.Ct. 946.
T17 When applied to this case, the relevant considerations identified in McArthur do not support a finding of exigency. While no one disputes that the odor of burning marijuana was evidence of a "crime or contraband" in the trailer, the only basis upon which the police could conclude that Ms. Duran would "destroy" the evidence before a warrant could be obtained was their belief that she would "smoke it up." Unlike Mr. McArthur, who knew that the police were onto him, Ms. Duran did not know that law enforcement officers were aware of the presence of marijuana in the trailer until they broke through the door. Most significantly, there is no indication that the law enforcement officers engaged in any effort, much less a reasonable one, to reconcile their law enforcement needs with the demands of personal privacy. In fact, to the extent that the officers engaged in any assessment of competing interests related to the acquisition of a warrant, they balanced their desire to avoid the inconvenience of seeking a warrant against Ms. Duran's privacy interests and concluded that convenience was more important. We cannot countenance this attempt at "reconciliation" and at the same time keep faith with our duty to interpret and apply [800]*800fundamental constitutional guarantees. therefore affirm the court of appeals. We
[[ 18 Chief Justice DURHAM, Justice DURRANT, and Justice PARRISH concur in Justice NEHRINGS opinion.