State v. Steven T. Delap, 913 N.W.2d 175

Police had two valid outstanding arrest warrants for Steven Delap and located him near a duplex they believed contained 110 Milwaukee St., Delap's reported address.
Officers (in uniform) approached; a man (later identified as Delap) turned, looked at them, and ran toward the rear door of the duplex after officers shouted "Stop, police." Officers chased him into the home, forced the rear door open, tasered and arrested him.
A search incident to arrest produced syringes and a smoking tube found in Delap's pocket; he was charged with obstructing an officer and possession of drug paraphernalia (both as a repeater).
Delap moved to suppress, arguing the driveway stop, pursuit into the home, and the search were unlawful under the Fourth Amendment and the Wisconsin Constitution.
The circuit court denied suppression (oral decision cited Payton but written order relied on "hot pursuit"); the court of appeals affirmed on hot pursuit; the Wisconsin Supreme Court affirmed on Payton grounds (declining to decide hot pursuit).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers could enter home to execute arrest warrants	State: Valid arrest warrants + facts supported reasonable belief Delap lived and was inside; Payton permits entry to effect arrest	Delap: Officers unlawfully chased and entered home; lacked probable cause that the fleeing man was Delap or that he lived there	Held: Entry lawful under Payton — officers had probable cause to believe Delap was the subject and resided/was present in the dwelling, so execution of warrants and seizure incident to arrest were lawful
Whether the officers had probable cause to identify the fleeing man as Delap and as a resident of the duplex	State: Prior reports, teletype, officers’ observation of flight from uniformed officers near 110 Milwaukee St. supported probable cause	Delap: Officers lacked personal knowledge that warrants were supported by probable cause and lacked basis to identify him or link him to the address	Held: Rejected Delap’s challenge — Payton requires only a valid arrest warrant and reasonable belief the suspect lives/is present; officers need not possess personal knowledge of the magistrate’s probable-cause finding
Whether the search incident to arrest and evidence seizure were lawful	State: Search incident to a lawful arrest justified seizure of items found on person	Delap: Seizure was tainted by unlawful entry/arrest	Held: Search incident to this lawful Payton arrest was proper; evidence admitted

Payton v. New York, 445 U.S. 573 (1979) (an arrest warrant implicitly authorizes limited entry into a suspect’s dwelling when there is reason to believe the suspect is inside)
Steagald v. United States, 451 U.S. 204 (1981) (an arrest warrant authorizes a limited invasion of privacy necessary to effect arrest in the home)
Santana v. United States, 427 U.S. 38 (1976) (hot pursuit can justify warrantless entry when a suspect flees from public into a dwelling)
Welsh v. Wisconsin, 466 U.S. 740 (1984) (seriousness of underlying offense is relevant to exigent-circumstances analysis)
State v. Weber, 372 Wis. 2d 202 (2016) (Wisconsin hot-pursuit/exigent-circumstances framework discussed)