James Lee Paul v. State of Indiana, 971 N.E.2d 172

Paul murdered Burns, Sr.’s son, during a night-time attack at 36 West Iowa; the body was found shortly after by police.
After the murder, Wroten identified Paul as the killer and led officers to Paul’s residence at 30 East Virginia.
Police arrested Paul inside his apartment without a warrant, after observing him tampering with Burns’ bicycle from a stairway.
A subsequent search warrant was obtained and executed, yielding the bicycle, bloody clothing, backpack, and other evidence.
Paul moved to suppress all apartment-derived evidence as unlawfully seized without a warrant or exigent circumstances; the court denied the motion.
Paul was convicted of murder and received a sixty-five-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was admission of apartment-seized evidence proper?	Paul contends Payton requires exclusion without exigent circumstances.	State alleges exigent circumstances due to danger and tampering with evidence.	Yes; exigent circumstances justified warrantless arrest and admission of evidence.
Is the sixty-five-year sentence inappropriate?	Sentence is excessive given mitigating factors.	Nature of offense and offender character support the maximum sentence.	No; sentence not inappropriate.

Payton v. New York, 445 U.S. 573 (U.S. 1980) (warrantless home entry generally prohibited absent exigent circumstances)
State v. Straub, 749 N.E.2d 593 (Ind. Ct. App. 2001) ( Fourth Amendment protections; exigent circumstances in home arrests)
Welsh v. Wisconsin, 466 U.S. 740 (U.S. 1984) (exigency and gravity of offense relevant to warrantless entry)
Sapen v. State, 869 N.E.2d 1273 (Ind. Ct. App. 2007) (exigency and probable cause in warrantless arrests)
Adkisson v. State, 728 N.E.2d 175 (Ind. Ct. App. 2000) (exigencies allowing warrantless arrest/search in certain contexts)
Woodson v. State, 966 N.E.2d 780 (Ind. Ct. App. 2012) (analysis of admissibility of evidence in context of warrantless entry)