State v. Bolt
In State v. Bolt, 142 Ariz. 260, 263, 689 P.2d 519, 522 (1984), police officers "secured" a residence by entering while they awaited a telephonic warrant and searching anywhere suspected co-conspirators in a drug ring might be hiding.
The Arizona Supreme Court first determined that federal law was not conclusive on this issue. Id. at 264.
It then concluded that, absent exigent circumstances, such police action would nevertheless be unconstitutional under our state constitution. Id. at 264-65.
In Bolt, the court declined to follow the United States Supreme Court's holding in Segura v. United States, 468 U.S. 796, 104 S. Ct. 3380, 82 L. Ed. 2d 599 (1984), which had approved a warrantless entry of a home in the absence of exigent circumstances.
The Arizona court held instead that, "in the absence of exigent circumstances or other necessity," police officers may without a warrant secure premises by preventing ingress or egress but may not enter a home until a search warrant can be obtained. Bolt, 142 Ariz. at 265, 689 P.2d at 524.