United States v. Santana

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.