## Facts

- Undercover Philadelphia police arranged a heroin purchase through Patricia McCafferty, who said the supply would come from Dominga “Mom” Santana.
- The officer recorded serial numbers on $110 in marked bills, gave the money to McCafferty, and drove her to Santana’s house.
- McCafferty entered the house, returned with heroin, and was arrested; she stated Santana possessed the marked money.
- Officers went to Santana’s residence and saw Santana standing in the open doorway holding a brown paper bag.
- When officers identified themselves and approached, Santana retreated into the vestibule; officers followed and caught her inside after a brief struggle.
- During the struggle, two heroin envelopes fell from the bag; marked money was found on Santana’s person.
- William Alejandro, who was outside on the steps, attempted to flee with the dropped envelopes and was apprehended.

## Issues

1. Whether Santana’s presence in the open doorway was a “public place” permitting a warrantless arrest upon probable cause under the Fourth Amendment.
2. Whether officers could enter the home without a warrant to complete the arrest after Santana retreated inside, under “hot pursuit” and exigent circumstances.
3. Whether the heroin and marked money were admissible as fruits of a lawful arrest and a search incident to that arrest.

## Decision

- The Supreme Court reversed the suppression order in a 7–2 decision.
- The Court held that Santana, standing in the open doorway, was in a public place for Fourth Amendment purposes; officers with probable cause could lawfully initiate a warrantless arrest there.
- The Court held Santana could not defeat a lawful public-place arrest by retreating into the home; the officers’ immediate pursuit and risk of evidence destruction justified warrantless entry.
- The heroin that fell during the struggle and the marked money found on Santana were admissible as seized incident to a lawful arrest; the seizure of the envelopes associated with Alejandro was also upheld.

## Legal Principles

- A person voluntarily standing in an open doorway is exposed to public view, hearing, speech, and touch and lacks a reasonable expectation of privacy for purposes of a warrantless arrest based on probable cause.
- Police may not be forced to abandon a lawfully initiated public-place arrest when the suspect retreats into a dwelling; immediate pursuit may qualify as hot pursuit even if brief.
- Exigent circumstances, including a reasonable belief that evidence will be destroyed if action is delayed, can justify warrantless entry to complete an arrest.
- When entry and arrest are lawful, officers may seize evidence as part of a search incident to arrest, including items falling from the arrestee’s possession and contraband or instrumentalities found on the arrestee.

## Conclusion

The Court held that a suspect in an open doorway may be arrested without a warrant on probable cause and that officers may follow the suspect into the home without a warrant to complete the arrest when immediate pursuit and risk of evidence destruction create exigent circumstances, making the resulting seizures admissible.


United States v. Santana, 427 U.S. 38 (1976)