Is there any CCA case law that permits law enforcement warrantless exigent entry to a residence following 'hot pursuit'? The hot pursuit does stem from a beer run theft and motor vehicle evading.

I have found SCOTUS case law however am looking for Texas CCA.

One place to start: Yeager v. State, 104 S.W.3d 103, Tex.Crim.App.,2003.

In Yeager the "hot pursuit" issue is an arrest outside the officer's jurisdiction but both the opinion and the dissenting opinion mention warrantless entry and cite federal caselaw.

So what I'm saying is, this CCA case from 2003 doesn't answer your question but it does show that the CCA is aware and follows the federal case law and it may also be a handy place to start for additional research of the cases cited in the opinion.

Here's a US Supreme Court case:

The District Court was correct in concluding that “hot pursuit” means some sort of a chase, but it need not be an extended hue and cry “in and about (the) public streets.” The fact that the pursuit here ended almost as soon as it began did not render it any the less a “hot pursuit” sufficient to justify the warrantless entry into Santana's house.
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We thus conclude that a suspect may not defeat an arrest which has been set in motion in a public place, and is therefore proper under Watson, by the expedient of escaping to a private place.


United States v. Santana, 427 U.S. 38, 42-43, 96 S.Ct. 2406, 2410, 49 L.Ed.2d 300 (1976).

That Santana decision was discussed in Yeager.

They are not from the CCA, but Houston-1st District has discussed entering a home following a hot pursuit of a suspect evading in a motor vehicle. Both were DWI cases. The first is Winter v. State, 902 S.W.2d 571, and the second is Vermillion v. State, 1997 Tex. App. LEXIS 6331, in which the court followed its reasoning in Winters.

Janette A

Texas case law allows entry into a home if you have a felony warrant and a reasonable belief the subject is inside. Since exigent circumstances typically negate the need for a warrant, this might be analagous on felony pursuits. Just a thought from someone too lazy to dig into the books.

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Originally posted by JohnW:
Texas case law allows entry into a home if you have a felony warrant and a reasonable belief the subject is inside. Since exigent circumstances typically negate the need for a warrant, this might be analagous on felony pursuits. Just a thought from someone too lazy to dig into the books.

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Yes I was just looking into actual case citations where this is allowed specifically opinions from Texas CCA or regional COAs. I appreciate everyone's help and input to my question. Thank You.