In promulgating this rule in Payton v. New York (1980), the U.S. Supreme Court opted to require an arrest warrant rather than a search warrant. This affects the way exceptions to the requirement, such as 'exigent circumstances,' are created and impacts police field procedures. The confusion generated by 'Payton' in both of these areas undermines the Supreme Court's intention to clarify the inhouse arrest-warrant issues. An examination of the reasoning in 'Payton' and the Court's inconsistent application of the rule in subsequent cases support the conclusion that the Court's selection of the arrest warrant was inappropriate. The 'Payton' Court's legacy has presented lower courts with the difficulty of applying arrest warrant exceptions to situations that turn upon search and seizure issues. Also, the uncertainties in the doctrine have significantly reduced the efficiency of police officials attempting to comply with often conflicting rules. 169 footnotes.