Commonwealth v. Talbert

In Commonwealth v. Talbert, 23 Va. App. 552, 478 S.E.2d 331, 334 (Va.Ct.App. 1996), the court explained that "a pursuit is 'hot' if the circumstances are such that breaking off or delaying the chase for the time required to obtain a warrant is likely to involve significant danger to any person, loss of evidence or opportunity for the suspect to escape."