The cop can come up with justification but ultimately it’s the judge’s decision to authorize the search warrant. The cop can’t just bust in without approval from those higher up, no matter what justification the cop gives. It depends on the laws of the area ultimately. This is where it helps to become extremely educated about the local laws and restrictions.
In my area it’s impossible for that to happen because I live out of town. I don’t have a sidewalk and any info they could get from the road wouldn’t be helpful.