What is the current state of the law on warrantless arrest?

5 United States v. Mejias, 552 F.2d 435, 444-45 (2d Cir. 1977); United States v. Fernandez, 480 F.2d 726, 740 n.20 (2d Cir. 1973); United States v. Hall, 348 F.2d 837, 841 (2d Cir.), cert. denied, 382 U.S. 947, 86 S.Ct. 408, 15 L.Ed.2d 355 (1965). In all of the government's cases, exigent circumstances were present or consent to entry was given. The issue when exigent circumstances are clearly not present has apparently not been faced directly in this circuit. The government argues that fear that appellant might flee the country supplied the exigent circumstances here. Since the agents had cleared the probable cause question with the prosecutor one day before and made no showing that a warrant could not be obtained without causing delay, we doubt that the reason advanced could alone validate a warrantless arrest.