People v. Santovi

Court properly granted Defendant's petition to rescind statutory summary suspension, as officer made illegal arrest when officer threatened to kick bathroom door down. Officer's statement compelled compliance, and made clear that Defendant was not at liberty to ignore officer's request. A reasonable person would not believe she was free to deny officer's demand or end encounter with police. Thus, conduct was an arrest for Fourth Amendment purposes. Hot pursuit exception is inapplicable, as arrest was not initiated in public, and Defendant was not fleeing from police. (LYTTON and O'BRIEN, concurring.)