Johnson v. United States

In Johnson v. United States, 333 U.S. 10, 68 S. Ct. 367, 92 L. Ed. 436 (1948), the Supreme Court decided that it was illegal for the police to make a warrantless arrest of appellant in, and a warrantless search of, her hotel room. See Johnson, 68 S. Ct. at 370. The Supreme Court stated that it could find "no element of 'hot pursuit' in the arrest of one who was not in flight, was completely surrounded by agents before she knew of their presence, who claims without denial that she was in bed at the time, and who made no attempt to escape." See Johnson, 68 S. Ct. at 370 n.7. The Supreme Court did not decide that the "hot pursuit" doctrine applies only when there is a "chase" and "escape."