The following excerpt is from United States v. Allen, 813 F.3d 76 (2nd Cir. 2016):
A rule that permitted an arrest "across the threshold," but allowed the arrested person to refuse the arrest simply by closing the door, would not be viable, for it would undermine the authority of the police and encourage resistance by those who were aware of the rule. The "right to remain literally at [an arrestee's] elbow," Washington v. Chrisman, 455 U.S. 1, 6, 102 S.Ct. 812, 70 L.Ed.2d 778 (1982), attaches immediately upon arrest. But if that is so, then an arrest "across the threshold" will often lead to the very intrusion into the home that Payton warns is the "chief evil" against which the warrant requirement protects. 445 U.S. at 585, 100 S.Ct. 1371.
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