Officers sticking their feet in the door

Officers may not stick their foot in the door to keep an occupant from closing the door unless there is a theory for entering the premises.

The theories are:
PC - Warrant
PC - Exigency
Emergency
Consent

Putting your foot in the door is a "search" under the 4th Amendment.

In People v Klimek officers talked to some people in an upstairs apartment who were complaining about Klimek making too much noise in the apartment below.

Officers knocked on Klimek's door. A female came to the door and said Klimek was too sick to come out. As she was going back into the apartment, the officer stuck his foot in the door. someone closed the door on his foot.

The court ruled that putting the foot in a door was a search and that there was no exigency in this case.

Best -

DA