Police officers chased her through the open door, causing packets of heroin to spill out of the paper bag that she had been holding, and arrested her in the vestibule of her home. Id. at 40-41, 96 S.Ct. 2406. The exigent circumstance of “hot pursuit” excused the warrant requirement. Id. at 42-43, 96 S.Ct. 2406. See also Welsh v. Wisconsin, 466 U.S. 740, 750, 104 S.Ct. 2091, 80 L.Ed.2d 732 (1984) (describing Santana as a case involving “hot pursuit of a fleeing felon”). Santana does not govern this case because the government has never contended that exigent circumstances existed here. 10 . To the extent that Titemore may be read broadly to permit law enforcement officers to enter curtilage to search for evidence, that broad holding has been abrogated by Jar-dines, 133 S.Ct. at 1416 (<HOLDING>). 11 . To the extent the government argues that
holding based on steelman and johnson that evidence of the smell of marijuana emanating from a home a car with an open door and the keys in the ignition in front of the home and pry marks on the homes front door was not sufficient to justify a warrantless entry holding a dog sniff outside the defendants front door was not a fourth amendment search holding that a drug sniff outside the front door of the defendants residence was not a fourth amendment search because the defendant had no reasonable expectation of privacy at the entrance to property that is open to the public including the front porch holding that background social norms that invite a visitor to the front door do not invite him there to conduct a search holding an elaborate ruse to invite defendants to rob a fictitious stash house was not outrageous