home implicated a different strand of Fourth Amendment doctrine not at issue here — that "even.if armed with an arrest warrant, police must generally have a search warrant to enter lawfully a third person's home.” Joyce, 112 F.3d at 21-22 (citing Steagald, 451 U.S. at 212-13, 101 S.Ct. 1642). 7 . Defendants argue that the arrest became "in-progress” and. a "hot pursuit” began when the police announced that Morse was under arrest and threatened to enter the home, but Morse did not surrender. However, it was well-established in 2009 that circumstances deliberately created by the police cannot give-rise to an exigency that justifies a warrantless entry. See United States v. Curzi, 867 F.2d 36, 43 n.6 (1st Cir.1989); see also United States v. Rengifo, 858 F.2d 800, 804 (1st Cir.1988) (<HOLDING>), abrogated by Kentucky v. King, 563 U.S. 452,
holding that once the scene was secure exigent circumstances no longer existed and the police were required to obtain a search warrant holding that exigent circumstances were created by dissipation of bloodalcohol content in time needed to obtain a warrant recognizing that  exigent circumstances do not excuse the failure to secure a warrant when those circumstances are created by government officials who unreasonably and deliberately delay or avoid obtaining the warrant recognizing exigent circumstance exception to warrant requirement holding that absent consent or exigent circumstances law enforcement officers cannot legally search for the subject of an arrest warrant in the home of a third party without first obtaining a search warrant