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City of Middletown v. Flinchum
Citations: 95 Ohio St. 3d 43; 765 N.E.2d 330Docket: No. 01-233
Court: Ohio Supreme Court; April 10, 2002; Ohio; State Supreme Court
On April 23, 1999, police officers in Middletown observed Thomas Flinchum engaging in reckless driving behavior, including spinning his tires at a red light and fishtailing as he made a turn. When officers attempted to approach him, he fled. After pursuing him, Officer Wayne Birch saw Flinchum enter his home and, without permission, entered to arrest him. Flinchum was charged with reckless operation, DUI, and resisting arrest. He moved to suppress the evidence from the warrantless entry, but the trial court denied the motion, citing "hot pursuit" as justification for the entry. Flinchum was convicted of reckless operation and DUI but acquitted of resisting arrest. The appellate court upheld the trial court’s decision. The court addressed whether the Fourth Amendment permits warrantless entry for a misdemeanor arrest. It affirmed the lower court's ruling, stating that flight from police cannot justify avoidance of arrest, emphasizing that hot pursuit allows for entry into a home. The court referenced prior rulings to support that a suspect cannot evade arrest by escaping into a private residence after committing an offense in public. Warrantless entry into a suspect's home by police is permissible when officers are in hot pursuit of a fleeing suspect, regardless of whether the underlying offense is a felony or misdemeanor. The case reinforces that fleeing from lawfully identified police officers does not grant the suspect the right to evade arrest by retreating into a private residence. The ruling aligns with precedents set in Nebraska v. Penas and Minnesota v. Paul, which establish that individuals cannot obstruct valid police actions by escaping to private spaces. While this decision grants police the authority to act without a warrant in specific circumstances, it maintains that such authority is not unlimited and must adhere to the Fourth Amendment's protections. The judgment in this case was affirmed, with some justices concurring and one dissenting.