In Vale v. Louisiana, 399 U.S. 30, 90 S. Ct. 1969, 26 L. Ed. 2d 409 (1970), the Supreme Court decided that it was illegal for the police to make a warrantless search of the defendant's home immediately after the police validly arrested the defendant on the front steps of his home pursuant to a warrant. See Vale, 90 S. Ct. at 1972. The Supreme Court decided that no exigent circumstances justified the warrantless search in part because the police "were not in hot pursuit of a fleeing felon." See id. The Supreme Court did not decide that the "hot pursuit" doctrine applies only when there is a pursuit of a fleeing or escaping felon.