In United States v. Santana, 427 U.S. 38 (1976), the police, with probable cause but without a warrant, drove to within fifteen feet of the defendant's home. Id., at 40, 42. The defendant was standing in the doorway of her house when the police arrived. Id., at 40. The defendant in Santana "was standing directly in the doorway--one step forward would have put her outside, one step backward would have put her in the vestibule of her residence." United States v. Santana, supra, 427 U.S. at 40 n.1. The police exited their van, shouting, "Police," and displaying identification. Id. As the police approached, the defendant retreated into the vestibule of her home. Id. The police followed her through the open door and arrested her inside her home. Id. In determining that Santana's arrest was proper and did not violate her fourth amendment rights, the court held that (1) when the police officers first sought to arrest the defendant, she was in a public place and (2) the officers' entry into her home, to complete the arrest, was proper under the "hot pursuit" exception to the warrant requirement. Id., at 42-43. In reaching its conclusion that the defendant in Santana was in a public place when the officers first sought to arrest her, the court concluded that by standing in her doorway, the defendant was "as exposed to public view, speech, hearing, and touch as if she had been standing completely outside her house," and that she was thus "not in an area where she had any expectation of privacy." Id., 427 U.S. at 42. Santana thus has come to stand for a kind of doorway exception or principle whereby "a person standing in the doorway of a house is in a public place, and hence subject to arrest without a warrant permitting entry of the home.".