United States v. Allen, 813 F.3d 76

Officers arrested Allen at his apartment door while he remained inside the home; they did not obtain a warrant.
The officers had formed a plan to arrest Allen without a warrant after identifying him as the suspect in an assault.
Allen opened the door, spoke with officers from the threshold, and could not return upstairs unless accompanied by officers.
Inside the apartment, Allen was searched and drugs/paraphernalia were observed, leading to a search warrant and later a federal arrest for felon in possession of a firearm.
The district court held the arrest occurred across the threshold and did not violate Payton; the defense challenged this as a Fourth Amendment violation.
The court ultimately vacated the conviction, reversed the suppression denial, and remanded, holding that an arrest inside the home following summons at the door requires a warrant absent exigent circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Payton’s protections apply to an arrest where the suspect remains inside the home	Allen (plaintiff) argues across-the-threshold arrest violates Payton	Government maintains location of arresting officers governs the rule	Payton applies based on the suspect’s location; restraint inside the home requires a warrant.
Whether Reed governs the admissibility of evidence where officers summon to the door and arrest inside the home	Reed supports suppression of arrest in home if no warrant	Reed should control only in its factual scenario	Reed compels that an arrest inside the home in response to summons requires a warrant if no exigency.
Role of constructive/coercive entry doctrine in limiting Payton	Constructive entry not needed to trigger Payton; Reed controls	Constructive/coercive entry could justify arrest without entering	Rejects constructive-entry theory; rule follows Reed and Payton.
Whether Hodari D. framework applies to in-home encounters	Hodari D. framework does not apply to in-home arrests	Hodari D. controls when arrest occurs by submission in street context	Hodari D. not applicable; totality-of-the-circumstances framework governs.
Policy/rationale of home protections in Payton vs. threshold-crossing arrests	Home has heightened Fourth Amendment protections; location matters	Practical enforcement requires flexible approach	Rule anchored in Reed/Payton: arrests inside home or at threshold without warrant require exigent circumstances.

Payton v. New York, 445 U.S. 573 (1980) (arrest inside home without warrant presumptively unreasonable)
Reed v. United States, 572 F.2d 412 (2d Cir.1978) (arrest inside home requires warrant absent exigency)
United States v. Santana, 427 U.S. 38 (1976) (hot pursuit; door opened; arrest in vestibule under exigent circumstances)
United States v. Hodari D., 499 U.S. 621 (1991) (arrest requires physical force or submission to authority; street context)
Gori v. United States, 230 F.3d 44 (2d Cir.2000) (discusses threshold doctrine in context of door delivery observation)
Titemore v. United States, 437 F.3d 251 (2d Cir.2006) (approach of officers to home for questioning; not directly a home-arrest scenario)
Florida v. Jardines, 133 S. Ct. 1409 (2013) (home is first among equals in Fourth Amendment)
Reed (listed again for emphasis), 572 F.2d 412 (2d Cir.1978) (precedent binding on the panel)