In Payton v. New York, 445 U.S. 573 (1980), the United States Supreme Court resolved two New York appeals. The first involved the admissibility of plain-view evidence seized when the police entered a locked apartment, Theodore Payton's residence. They had gone to the address to arrest Payton for murder. They had not obtained either an arrest warrant or a search warrant. Rather, they were acting pursuant to state statutes "authorizing police officers to enter a private residence without a warrant and with force, if necessary, to make a routine felony arrest." Id., 445 U.S. at 574. No one was present in the apartment when the police broke open the door and entered. They seized a .30 caliber shell casing in plain view that was later admitted into evidence at Payton's murder trial. The trial court held the warrantless and forcible entry to have been authorized by statute and denied the motion to suppress the plain-view evidence. Id., 445 U.S. at 577-78. The second appeal in Payton involved facts and a search similar to the one at issue here, but also, as in Theodore Payton's case, occurring at the defendant's own home. There, the police went to Obie Riddick's house, also without an arrest warrant or a search warrant, to arrest him for two armed robberies. When his young son opened the door, they could see Riddick sitting in bed covered by a sheet. They entered the house and placed him under arrest. Before permitting him to dress, they opened a chest of drawers two feet from the bed in search of weapons and found narcotics and related paraphernalia. Riddick was subsequently indicted on narcotics charges. At a suppression hearing, the trial judge held that the warrantless entry into his home was authorized by the revised New York statute, . . . and that the search of the immediate area was reasonable under Chimel v. California, 395 U.S. 752, 89 S. Ct. 2034, 23 L. Ed. 2d 685, reh'g denied, 396 U.S. 869, 90 S. Ct. 36, 24 L. Ed. 2d 124 (1969). . . .445 U.S. at 578-79, 100 S. Ct. at 1376, 63 L. Ed. 2d at 646. The Supreme Court reiterated the "basic principle of Fourth Amendment law" that searches and seizures inside a home without a search warrant are presumptively unreasonable; that such a search can be upheld only if the police can show that it "falls within one of a carefully defined set of exceptions based on the presence of 'exigent circumstances,'" (quoting from Coolidge v. New Hampshire (1971) 403 U.S. 443 29 L.Ed.2d 564, 91 S.Ct. 2022). The United States Supreme Court announced the principle that a warrant for an arrest inside a home is constitutionally required in the absence of exigent circumstances. The court also noted that "we are dealing with entries into homes made without the consent of any occupant." ( Payton, supra, 445 U.S. 573, 583 63 L.Ed.2d 639, 649.) The United States Supreme Court reaffirmed the overarching significance, under the fourth amendment, of the sanctity of the home. . . . The court stated . . . The Fourth Amendment protects the individual's privacy in a variety of settings. In none is the zone of privacy more clearly defined than when bounded by the unambiguous physical dimensions of an individual's home--a zone that finds its roots in clear and specific constitutional terms: The right of the people to be secure in their . . . houses . . . shall not be violated. That language unequivocally establishes the proposition that at the very core of the Fourth Amendment stands the right of a man to retreat into his own home and there be free from unreasonable governmental intrusion." (Payton v. New York, supra, 445 U.S. at 589-90.) The United States Supreme Court also made it clear that "in terms that apply equally to seizures of property and to seizures of persons, the Fourth Amendment has drawn a firm line at the entrance to the house. Absent exigent circumstances, that threshold may not reasonably be crossed without a warrant." (Payton v. New York, supra, 445 U.S. at 590.)