In Welsh v. Wisconsin, 466 U.S. 740 (1984), the driver lost control of his car and came to a stop in a field without causing any injury or property damage. A witness who saw the driver walk away told the officers that the driver was inebriated or sick. The officers went to the driver's nearby house, entered, and arrested him. (Welsh, supra, 466 U.S. at pp. 742-743.) The court held there were no exigent circumstances to justify the warrantless arrest because in the State of Wisconsin, driving while intoxicated was a "noncriminal, civil forfeiture offense for which no imprisonment" was possible, and there was no immediate or continuous pursuit from the scene of the crime. (Id. at pp. 753-754.) Thus, the warrantless entry was improper. (Id. at p. 754.) The Welsh court declined to consider whether the Fourth Amendment imposed an absolute ban on warrantless home arrests for minor offenses, focusing instead on whether the offense was jailable. (Welsh, at p. 749, fn. 11.) The United States Supreme Court concluded a warrantless nighttime entry into the petitioner's home to arrest him violated the Fourth Amendment to the United States Constitution, and therefore vacated the judgment of conviction. (Welsh v. Wisconsin, supra, at p. 754.) The primary factors relied on by the Court were the lack of gravity of the crime committed by the petitioner--driving while intoxicated, which the state of Wisconsin had classified as a noncriminal, civil forfeiture offense for which imprisonment was not permitted--and the lack of any threat to public safety posed by the petitioner, who had abandoned his car and walked home. (Id. at pp. 753-754.) In Welsh v. Wisconsin, the intoxicated defendant abandoned his car in an open field in the middle of the night and fled to his home a short distance away. See Welsh, 104 S. Ct. at 2093-94. A few minutes later, the police arrived at the location of the defendant's abandoned car, they developed probable cause to believe that the defendant had been driving while intoxicated, and they determined where the defendant lived. See id. Not long after this, the police without a warrant entered the defendant's home and arrested the naked defendant in his bedroom for DWI which, under state law, was a nonjailable offense. See Welsh, 104 S. Ct. at 2094-96. The Supreme Court held that the Fourth Amendment "prohibits the police from making a warrantless night entry of a person's home in order to arrest him for a nonjailable traffic offense." See Welsh, 104 S. Ct. at 2093, 2099. The Supreme Court also decided that the government's claim of "hot pursuit was unconvincing because there was no immediate or continuous pursuit of the defendant from the scene of a crime." See Welsh, 104 S. Ct. at 2099. The Court held that a "minor offense" would ordinarily not generate the "exigent circumstances" which would justify a warrantless search or arrest in the suspect's home. In Welsh, the police violated the defendant's Fourth Amendment rights by arresting him in his home without a warrant for driving while intoxicated. The Court emphasized that "the police bear a heavy burden when attempting to demonstrate an urgent need that might justify warrantless searches or arrests." Id. at 749-50. The opinion notes that only "hot pursuit of a fleeing felon," "destruction of evidence," and "ongoing fire" were recognized by the Court as emergency situations justifying a warrantless search or arrest and that only the "hot pursuit" doctrine was applied to arrests in the home. Id. at 750. In language that is particularly pertinent to the cases before us, the Court continues: Our hesitation in finding exigent circumstances, particularly when warrantless arrests in the home are at issue, is especially appropriate when the underlying offense for which there is probable cause to arrest is relatively minor. Before agents of the government may invade the sanctity of the home, the burden is on the government to demonstrate exigent circumstances that overcome the presumption of unreasonableness that attaches to all warrantless home entries. When the government's interest is only to arrest for a minor offense, that presumption of unreasonableness is difficult to rebut, and the government usually should be allowed to make such arrests only with a warrant issued upon probable cause by a neutral and detached magistrate. Id. at 750.