Can Police Arrest a ''Flight Risk'' Suspect Without a Warrant ?
In People v. Yates, 98 Ill. 2d 502, 75 Ill. Dec. 188, 456 N.E.2d 1369 (1983), the court considered other circumstances which would suggest that the officers were justified in believing that the defendant must be arrested quickly.
In Yates, following a brutal murder the police learned that defendant's girlfriend was raising money to enable him to leave the state and that defendant had received a tip-off that the police were "hot on his trail." Yates, 98 Ill. 2d at 516.
The court held that, given the defendant's probable flight, a warrant would have delayed his apprehension and might have substantially increased possibility of flight and risk of a violent confrontation. Yates, 98 Ill. 2d at 516-17.