State v. Lam, 989 N.E.2d 100

Lam was convicted of possession of heroin after a no contest plea following a suppression motion ruling.
Police pursued Jeffrey Lam for a traffic violation and fled; officers knew past drug/firearm history with Jeffrey and Timothy.
The pursuit led to 645 Creighton Avenue; officers entered the Lam home with a battering ram after failing to open the door.
Inside, officers conducted a protective sweep, observed drugs in plain view, and obtained a search warrant.
Lam was arrested and heroin was found tied to his shorts; the suppression motion challenged warrantless entry and arrest.
Trial court overruled the suppression motion; Lam appealed challenging exigent circumstances and probable cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was entry into the home justified by hot pursuit or exigent circumstances?	Lam argues no exigent circumstances existed to justify warrantless entry.	Lam argues the minor misdemeanor flight does not create exigent circumstances.	No; entry upheld under hot pursuit as in Flinchum; suppression denied.

Santana v. United States, 427 U.S. 38 (1976) (hot pursuit cannot be thwarted by retreat into a home when probable cause exists)
Payton v. New York, 445 U.S. 573 (1980) (warrantless home entry generally prohibited without exigent circumstances)
Welsh v. Wisconsin, 466 U.S. 740 (1984) (exigency limits for warrantless entry in minor offenses)
Middletown v. Flinchum, 95 Ohio St.3d 43 (2002) (hot pursuit extends to misdemeanor arrests; police may enter to arrest fleeing suspect)
State v. Williams, 55 Ohio St.2d 82 (1978) (plain view and exigent circumstances considerations)