People v. Caputo, 155 A.D.3d 648

On Feb. 25, 2015, a detective observed Richard Caputo driving erratically and at high speed; the detective pursued with lights and siren after Caputo failed to stop.
During pursuit Caputo ran stop signs, drifted lanes, crashed his vehicle into a detached garage at a residential property (later identified as his home), and abandoned the running car with an open driver’s door and an empty beer bottle in the console.
The detective waited for backup, then entered the garage through an open side door without a warrant and found Caputo hiding in the rafters; officers handcuffed him inside the garage.
Caputo made incriminating statements and refused a chemical blood test; he was charged with multiple offenses including felony DWI (VTL § 1192(4-a)) and unlawful fleeing a police officer.
After the Supreme Court (Nassau County) denied suppression of statements, blood-test refusal, and physical evidence, Caputo pleaded guilty and appealed the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless entry into detached garage	Entry justified by hot pursuit and exigent circumstances due to dangerous flight and crash	Entry violated Fourth Amendment; garage is within home curtilage so warrant required	Court held hot pursuit/exigent circumstances justified warrantless entry into garage
Expectation of privacy/curtilage	Garage was within curtilage but warrant not required when suspect flees into residence during valid public arrest pursuit	Caputo argued garage is part of home and protected; entry thus unlawful	Court agreed garage was curtilage but ruled hot pursuit exception applied
Suppression of statements	Statements admissible as derivative of lawful arrest following valid entry	Statements should be suppressed as fruit of illegal entry	Court denied suppression of statements given entry was lawful under hot pursuit doctrine
Suppression of refusal to submit to blood test/physical evidence	Refusal and physical evidence admissible given lawful arrest and valid entry	Refusal and evidence tainted by illegal entry and should be suppressed	Court denied suppression; evidence admissible because entry was justified by hot pursuit

People v Levan, 62 N.Y.2d 139 (recognizes home entry as primary Fourth Amendment concern and no burden to show expectation of privacy)
United States v Santana, 427 U.S. 38 (hot pursuit permits warrantless entry when arrest begun in public and suspect retreats into home)
United States v Dunn, 480 U.S. 294 (defines curtilage and factors for determining if area is part of home)
Payton v New York, 445 U.S. 573 (limits warrantless home entries absent exigent circumstances)
People v McBride, 14 N.Y.3d 440 (discusses exigent circumstances permitting warrantless entry after dangerous flight)
People v Jenkins, 24 N.Y.3d 62 (emphasizes that warrantless home searches are per se unreasonable, subject to narrow exceptions)