Is a warrantless arrest warrant valid in exigent circumstances?

Although we need not reach the issue, it seems clear that exigent circumstances justified the police action here, permitting a warrantless arrest inside the house, even though the police chose the more prudent course of ordering the occupants from the house. (See Payton v. New York, supra, 445 U.S. at pp. 583-590.) The trial court reached a similar conclusion, but stated, "I don't know that the case necessarily has to rely on that, though."

A continuous investigative trail, beginning at the scene of the armed robbery, led the police to defendant a few hours later. They had reason to believe defendant was the armed perpetrator and that the gun was his; they had no reason to believe he was not still in possession of the gun. (See People v. Williams (1989) 48 Cal.3d 1112, 1138.)