when officers are in hot pursuit of a fleeing suspect felony, they need to stop to seek a warrant even if that creates a risk that the suspect will escape.

According to the "hot pursuit" exception to the warrant requirement, a defendant cannot avoid an accurate arrest by simply arriving home a few steps before following law enforcement. The phrase "hot pursuit" refers to the quick chase of a suspect who is running from law enforcement and has been used in the past to support warrantless entrance and arrest for both felonies and misdemeanors. According to United States V Williams, the emergency exception to the warrant requirement is "hot pursuit of a fleeing felon." According to Middletown V Flinchum, police who are hot on the trail of a suspect who enters a house to evade arrest are allowed to do so "without a warrant, regardless of whether the subject is being apprehended for a misdemeanor."

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