State v. Vanessa D. Hughes, 2000 WI 24, 233 Wis. 2d 280, 607 N.W.2d 621, reversing unpublished decision, cert. denied, __ U.S. __ (2001)
For Hughes: Andrea Taylor Cornwall, SPD, Milwaukee Appellate.
¶25 In Smith, we recognized four circumstances which, when measured against the time needed to obtain a warrant, constitute the exigent circumstances required for a warrantless entry. Id. at 229. Those circumstances are (1) an arrest made in “hot pursuit,” (2) a threat to safety of a suspect or others, (3) a risk that evidence will be destroyed, and (4) a likelihood that the suspect will flee. Id.