In Payton v. New York, the U.S. Supreme Court held that, absent exigent circumstances, a warrant must be obtained before suspects may be arrested in their homes. The court did not attempt to define which exigent circumstances would justify a warrantless entry. Although the courts agree on the major categories comprising exigent circumstances -- hot pursuit, destruction of evidence, threat of violence, and possibility of flight -- there has been little uniformity among decisions in each of these areas. Each case is decided on its particular facts, producing discontinuity in this area of law. The exigent circumstances exception to the warrant requirement is intended to apply only in emergency situations. Courts have often found exigent circumstances, however, even though an emergency situation did not exist. For this reason, a narrow definition of exigent circumstances is necessary. Exigent circumstances should be found only when the state can point to specific and articulable facts which indicate a compelling need for immediate police action. The focus of this analysis is on the facts known to the police in each case, not on considerations based on speculation or past circumstances. A total of 124 footnotes are listed. (Author summary modified)