This may sound like a simple problem, but I have a suppression hearing coming up that involves this issue. I just want to have all my bases covered. Defense atty will argue that my officers lacked PC and exigent circumstances to enter a fenced back yard on a disturbance/drug party call. The officers saw two individuals run into the residence when they approached the house, knocked on the front door--but no one answered, so they proceeded to the back yard. Once in backyard, officers saw numerous young people, alcohol, etc. through a sliding glass door. They made contact w/ Defendant through glass door, but he asked if they had a warrant w/o opening the door. Finally, he exits home onto back porch and is charged with Contributing to Minors.
My question concerns whether an anonymous informant, coupled with fleeing individuals and no answer at the front door---are enough to satisfy PC and exigent circumstances to enter curtilage (back yard)?

NPR had a story about this subject today...

Here is the teaser text:
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Morning Edition, April 24, 2006 � A court case that began with a simple complaint from a neighbor about a loud party has now landed in the Supreme Court. The justices will hear arguments that examine when, and for what reasons, police are authorized to enter a home.
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You can get the full story here:
http://www.npr.org/templates/story/story.php?storyId=5358614

Just cause two guys run into a house as police arrive is not gonna get you exigent circumstances. How long did the police knock at the front door? Did the police open a backyard gate or was there an unobstructed way of walking into the backyard?

My guess will be that the police cannot just go into the backyard without exigent circumstances, and I don't see any so far.

Good luck.