“Mr. Woods did not surrender his reasonable expectation of privacy when his wife answered a knock on the closed door of their home. Further, during the entire encounter, Mr. Woods stood behind his wife inside the home. As such, Mr. Woods was not in a ‘public place’ when the officers initiated the arrest,” determined the court. “The officers’ entry into Mr. Woods’ home without a warrant also was not justified given the absence of any exigent circumstances, such as the need to prevent the imminent destruction of evidence or to prevent a suspect’s escape.”

       

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