Vaneaton concedes that the police who arrested him for receiving stolen property had probable cause to do so, but he contends that the warrantless arrest violated the rule of Payton v. New York, 445 U.S. 573, 100 S. Ct. 1371, 63 L. Ed. 2d 639 (1980), a rule ordinarily requiring police to obtain a warrant before arresting a suspect inside his home, or in this case, inside his motel room.
The issue Vaneaton raises is whether the police, acting with probable cause but without a warrant and while standing outside his motel room, could lawfully arrest him while he was standing immediately inside the open doorway. Relying on Payton v. New York, 445 U.S. 573, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980), and denying the existence of exigent circumstances,