ABSTRACT
In August 1974 Philadelphia police officers approached "Mom" v. Santana's house with probable cause—but no warrant—to arrest her on felony drug distribution charges. Santana continued to assert that absent a warrant or dire emergency, the Fourth Amendment barred police officers from entering her private dwelling and arresting her inside. Seeing the officers, Santana quickly retreated from the front doorway—where she had been standing with a brown paper bag in hand—to the interior of the house. In a seven-two opinion by Justice William H. Rehnquist, the US Supreme Court rejected Santana's argument and expanded the "hot pursuit" exception to the Fourth Amendment's general warrant requirements. At issue in United States Santana, 427 US 38, was the scope of Fourth Amendment restrictions on warrantless arrests and searches within private residences.
