State v. Dugan, 276 P.3d 819

Dugan was involved in a hit-and-run collision; he left the scene and observers provided a description and tag number.
Lawrence police matched the SUV to Dugan and observed it entering his garage; Officer Scott intervened by sticking her foot under the closing garage door and entering the residence.
Dugan showed signs of intoxication and was arrested for DUI after failing field sobriety tests; breath test was refused.
Dugan moved to suppress all evidence obtained from inside the home, arguing the entry violated the Fourth Amendment.
The district court denied the suppression motion; Dugan was tried and convicted on DUI and related offenses.
The Court of Appeals reversed, holding the warrantless entry was unconstitutional and remanded for suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there a valid exigent circumstance to bypass the warrant?	Dugan	State	No exigency justified warrantless entry
Did hot pursuit justify entering the home without a warrant?	Dugan	State	Hot pursuit did not apply
Did potential loss of evidence create an exigency?	Dugan	State	Loss of evidence did not create exigency

Welsh v. Wisconsin, 466 U.S. 740 (U.S. 1984) (threshold crossings require warrants absent exigent circumstances)
Payton v. New York, 445 U.S. 573 (U.S. 1980) (home entry without warrant presumptively unreasonable)
Groh v. Ramirez, 540 U.S. 551 (U.S. 2004) (probable cause plus exigent circumstances required for warrantless entry)
Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency aid doctrine as warrant exception)
Minnesota v. Olson, 495 U.S. 91 (U.S. 1990) (hot pursuit considerations and exigency framework)
United States v. Santana, 427 U.S. 387 (U.S. 1976) (hot pursuit extends into residence when fleeing after crime in public place)
State v. Platten, 225 Kan. 764 (Kan. 1979) (Platten factors for evaluating exigent circumstances in warrantless entries)
State v. Thomas, 273 Kan. 750 (Kan. 2002) (integrated totality-of-circumstances approach to exigency)