In Payton, the court held that, absent consent or emergency circumstances, officers must obtain an arrest warrant to gain lawful entry to a suspect's residence. In Steagald v. United States, the Supreme Court addressed the issue of arrest of a suspect in a third party's home. It held that while an arrest warrant protected the suspect from unreasonable seizure, it did not protect the homeowner from unreasonable search and that a search warrant was necessary. The Court further concluded that exigent circumstances would excuse the need to obtain a search warrant when entry was necessary to accommodate legitimate law enforcement efforts. Numerous subsequent cases in the lower courts have addressed the question of what factors constitute exigent circumstances. Factors recurring in these decisions include: the gravity of the precipitating offense, the time between establishing probable cause and warrantless entry, destruction of evidence, likelihood of escape, danger to the safety of police and/or public, prior efforts to obtain a warrant (particularly the availability of telephonic warrants), and whether the exigency was created by the Government. A total of 48 footnotes are provided.