hot pursuit exception in Ohio

2018See United States v. Santana, 427 U.S. 38 , 42–43, 96 S.Ct. 2406 (1976). {¶23} In State v. Howard, 75 Ohio App.3d 760, 774-775 , 600 N.E.2d 809 (1991), this Court rejected an argument that the exigent circumstances, or the hot pursuit exception to the warrant requirement, applied to an entry by law enforcement into a residence of a third party to execute an arrest warrant upon a nonresident.

2018See United States v. Santana, 427 U.S. 38 , 42–43, 96 S.Ct. 2406 (1976). {¶23} In State v. Howard, 75 Ohio App.3d 760, 774-775 , 600 N.E.2d 809 (1991), this Court rejected an argument that the exigent circumstances, or the hot pursuit exception to the warrant requirement, applied to an entry by law enforcement into a residence of a third party to execute an arrest warrant upon a nonresident.

2018See United States v. Santana, 427 U.S. 38 , 42–43, 96 S.Ct. 2406 (1976). {¶23} In State v. Howard, 75 Ohio App.3d 760, 774-775 , 600 N.E.2d 809 (1991), this Court rejected an argument that the exigent circumstances, or the hot pursuit exception to the warrant requirement, applied to an entry by law enforcement into a residence of a third party to execute an arrest warrant upon a nonresident.

2018See United States v. Santana, 427 U.S. 38 , 42–43, 96 S.Ct. 2406 (1976). {¶23} In State v. Howard, 75 Ohio App.3d 760, 774-775 , 600 N.E.2d 809 (1991), this Court rejected an argument that the exigent circumstances, or the hot pursuit exception to the warrant requirement, applied to an entry by law enforcement into a residence of a third party to execute an arrest warrant upon a nonresident.

2015We relied on Middletown v. Flinchum, 95 Ohio St.3d 43 , 2002-Ohio-1625 , 765 N.E.2d 330 , in which the Supreme Court of Ohio, relying on United States v. Santana, 427 U.S. 38 , 96 S.Ct. 2406 , 49 L.Ed.2d 300 (1976), extended the hot pursuit exception to the search warrant requirement to misdemeanor offenses, stating, “we see no reason to differentiate appellant’s offense and give him a free pass merely because he was not charged with a more serious crime.

2015We relied on Middletown v. Flinchum, 95 Ohio St.3d 43 , 2002-Ohio-1625 , 765 N.E.2d 330 , in which the Supreme Court of Ohio, relying on United States v. Santana, 427 U.S. 38 , 96 S.Ct. 2406 , 49 L.Ed.2d 300 (1976), extended the hot pursuit exception to the search warrant requirement to misdemeanor offenses, stating, “we see no reason to differentiate appellant’s offense and give him a free pass merely because he was not charged with a more serious crime.

2015We relied on Middletown v. Flinchum, 95 Ohio St.3d 43 , 2002-Ohio-1625 , 765 N.E.2d 330 , in which the Supreme Court of Ohio, relying on United States v. Santana, 427 U.S. 38 , 96 S.Ct. 2406 , 49 L.Ed.2d 300 (1976), extended the hot pursuit exception to the search warrant requirement to misdemeanor offenses, stating, “we see no reason to differentiate appellant’s offense and give him a free pass merely because he was not charged with a more serious crime.

2013The U.S. Supreme Court held that the police, who had probable cause to arrest the defendant, could not be thwarted in that effort by the defendant’s retreat into her house. {¶ 18} In Middletown v. Flinchum, 95 Ohio St.3d 43 , 2002-Ohio-1625 , 765 N.E.2d 330 , the Supreme Court of Ohio, relying on Santana, extended the hot pursuit exception to the search warrant requirement to misdemeanor offenses, stating, “we see no reason to differentiate appellant’s offense and give him a free pass merely because he was not charged with a more serious crime.

2000Wendel at 6 . 5 A similar scenario was addressed in State v. Grubb (1993), 82 Ohio App.3d 187 , 191-192 , where Ohio State University police officers observed the defendant commit a traffic violation outside of the jurisdiction of the university police officers.

1999See, e.g. , State v. Smigelski (June 9, 1995), Lucas App. No. L-94-183, unreported, at 8-10, 1995 Ohio App. LEXIS 2434 (suggesting that the violation in Hollen occurred within the police officer's proper jurisdiction, thereby triggering the hot pursuit doctrine); Grubb , 82 Ohio App.3d at 192 (noting that Hollen "involved application of a `hot pursuit' doctrine, which is not present here").

2008See Middletown v. Flinchum, 95 Ohio St.3d 43, 44 , 2002-Ohio-1625 , 765 N.E.2d 330 (“a suspect may not avoid arrest simply by outrunning pursuing officers and finding refuge in her home”); State v. Stuber, 150 Ohio App.3d 200 , 2002-Ohio-6309 , 779 N.E.2d 1090, at ¶ 12 (deputies were engaged in hot pursuit of the suspect when the suspect fled from his driveway into his house upon sight of the deputies).

2008See Middletown v. Flinchum, 95 Ohio St.3d 43, 44 , 2002-Ohio-1625 , 765 N.E.2d 330 (“a suspect may not avoid arrest simply by outrunning pursuing officers and finding refuge in her home”); State v. Stuber, 150 Ohio App.3d 200 , 2002-Ohio-6309 , 779 N.E.2d 1090, at ¶ 12 (deputies were engaged in hot pursuit of the suspect when the suspect fled from his driveway into his house upon sight of the deputies).