Under what circumstances can police force entry into a residence to arrest without a search warrant?

The circumstances under which officers may enter a residence to arrest without a warrant are described in People v. Ramey (1976) 16 Cal.3d[104 Cal.App.3d 89] 263, 276, 127 Cal.Rptr. 629, 637, 545 P.2d 1333, 1341: "In this context, 'exigent circumstances' means an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to forestall the imminent escape of a suspect or destruction of evidence. There is no ready litmus test for determining whether such circumstances exist, and in each case the claim of an extraordinary situation must be measured by the facts known to the officers."

In People v. Escudero (1979) 23 Cal.3d 800, 153 Cal.Rptr. 825, 592 P.2d 312, the court sustained an arrest of a burglar who had been traced from the crime to his place of residence. The court said (at pp. 810-811, 153 Cal.Rptr. at p. 831, 592 P.2d at p. 318): "Throughout the events in question the police were pursuing a man whom they suspected of having broken into an occupied private home in the middle of the night to commit a burglary; this is a serious crime, with an ever-present potential for exploding into violent confrontation. The need to prevent the imminent escape of such an offender is clearly an exigent circumstance within the doctrine here invoked."

Also of interest is the statement on this subject appearing in People v. Wetzel, 11 Cal.3d 104, 113 Cal.Rptr. 32, 520 P.2d 416. In that case officers had forced entry into a residence trying to find one of three juveniles who had smashed the window of a store building at 4:00 a. m. The controlling issue in Wetzel was whether the female occupant of the residence was subject to arrest for obstructing an officer when she verbally protested the officers' entry. The court commenced its analysis of the situation with this statement: "Preliminarily it should be stated that the officers were clearly correct in their assertion that they did not need a search warrant in order to enter an apartment in hot pursuit of a criminal suspect. The citizen informant had provided them with fresh information which had already been proved to be reliable." (11 Cal.3d at p. 108, 113 Cal.Rptr. at p. 34, 520 P.2d at p. 418.)