The People v. Shawn J. Sivertson, 29 N.Y.3d 1006

Police responded to a convenience-store robbery; surveillance and employee accounts described a white male in his 50s armed with a small knife wearing coat, gloves, scarf.
Witnesses said someone matching the description had been seen earlier on the stoop of a nearby building; officers went to that building.
Officers observed defendant through lit apartment windows lying in bed and watching TV in a small rear apartment; they saw gloves on a kitchen table.
Officers knocked and shouted at the door and windows for ~10 minutes; defendant made eye contact, rolled over, and closed his eyes but did not exit or brandish a weapon.
Several officers forced open the door, arrested defendant, and seized hat, gloves, three small knives, scarf, and jacket; court suppressed jacket and scarf as seized from a closed container.
Trial court and Appellate Division found exigent circumstances justified the warrantless entry; dissent (Rivera, J.) argued the record lacks facts establishing an urgent need to enter without a warrant and would order a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exigent circumstances justified warrantless entry into defendant’s home	Officers had probable cause to ID defendant as robber armed with a knife, observed him inside apartment, and faced potential danger/escape risk — exigency justified entry	Defendant was passive, observed by officers through windows, did not threaten, flee, or access other parts of the building; sufficient time and resources existed to obtain a warrant	Court affirmed Appellate Division: record supports finding of exigent circumstances (lead opinion). Dissent: record does not establish an urgent need; entry unreasonable.
Whether items seized in apartment were lawfully seized	Items in plain view (hat, gloves, knives) were lawfully seized after lawful entry	Jacket and scarf taken from a closed container were unlawfully obtained	Trial court suppressed jacket and scarf as seized from a closed container; upheld seizure of plain-view items.

Florida v. Jardines, 569 U.S. 1 (2013) (home has heightened Fourth Amendment protection)
Payton v. New York, 445 U.S. 573 (1980) (warrantless home arrests presumptively unreasonable)
Katz v. United States, 389 U.S. 347 (1967) (warrant requirement and narrow exceptions)
Welsh v. Wisconsin, 466 U.S. 740 (1984) (government bears heavy burden to justify warrantless home entry)
Brigham City v. Stuart, 547 U.S. 398 (2006) (emergency-entry rule requires objective justification)
People v. McBride, 14 N.Y.3d 440 (2010) (factors for exigent-circumstances analysis)
People v. Jenkins, 24 N.Y.3d 62 (2014) (narrow construction of warrant exception for homes)