State v. Adams, ___ N.C. App. ___, 794 S.E.2d 357 (Dec. 6, 2016)

Exigent circumstances justified the officers’ warrantless entry into the defendant’s home to arrest him. It was undisputed that the officers had reasonable suspicion to stop the defendant for driving while license revoked. They pulled into the defendant’s driveway behind him and activated blue lights as the defendant was exiting his vehicle and making his way toward his front door. The defendant did not stop for the blue lights and continued hurriedly towards the front door after the officers told him to stop. “At that point,” the court explained, “the officers had probable cause to arrest defendant for resisting a public officer and began a ‘hot pursuit’ of defendant.” The officers arrived at the front door just as the defendant was making his way across the threshold and were able to prevent him from closing the door. The officers then forced the front door open and detained and arrested the defendant just inside the door. The court held that the warrantless entry and arrest was proper under United States v. Santana, 427 U.S. 38 (1976). It explained: Hot pursuit been recognized as an exigent circumstance sufficient to justify a warrantless entry into a residence where there is probable cause, without consideration of immediate danger or destruction of evidence.