Wren,(21) the Court of Appeals of Idaho ruled in a disturbing the peace case that it is not permissible for the police to make a warrantless entry if the sole reason for their entry is that they are in hot pursuit.
Warrantless Entries When Officers Not in Hot Pursuit
Under Hayden, even though officers are not chasing a suspect and therefore cannot be said to be in hot pursuit, they still may be permitted to enter a suspect's residence without stopping to obtain a warrant if to delay entering might give the suspect an opportunity to escape or harm the police or public.
The Dorman court found that the officers were not in hot pursuit of the suspect because the entry into the home came over 4 hours after the offense.
If police officers are in hot pursuit of a criminal suspect and chase that suspect to a house, most courts permit the officers to follow that suspect into the house to apprehend him.