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United States v. Santana


Officers had probable cause to believe that the defendant possessed marked money that had earlier been used in an undercover heroin buy. Upon arriving at the defendant’s residence, but without a warrant, officers observed her standing in the doorway to her home holding a paper bag. They got out of their vehicle, shouted “police,” and displayed their identification. The defendant turned and ran into the entryway of her home, where the officers pursued and seized her. The defendant struggled to escape the officers, at which time “two bundles of glazed paper packets with a white powder” fell out of the paper bag onto the floor. During a search of the defendant’s person, some of the marked money was discovered. The powder was later identified as heroin.


Whether the officers’ warrantless entry into the defendant’s home was justified under the Fourth Amendment?


Yes. The officers’ entry into the defendant’s home was justified because the officers were in “hot pursuit” of the defendant.


The Fourth Amendment is not violated when officers make a warrantless arrest in a public place for a felony offense. The question here is whether the defendant was in a public place. She was standing in her doorway when the officers first attempted to arrest her. “She was not merely visible to the public, but was as exposed to public view, speech, hearing, and touch as if she had been standing completely outside her house.” Once the defendant ran into her home, the officers were in “hot pursuit” of her. Had the officers failed to act quickly in this case, “there was a realistic expectation that any delay would result in the destruction of evidence.” For that reason, the warrantless entry into the defendant’s home was reasonable under the Fourth Amendment. After her lawful arrest, the search that produced the drugs and the marked money was incident to that arrest and, therefore, lawful.


427 U.S. 38, 96 S. Ct. 2406 (1976)

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