Is a search warrant necessary to enter a suspect's home when they have an arrest warrant for the suspect?

Law enforcement authorities generally do not need a search warrant to enter a suspect's home when they have an arrest warrant for the suspect, as "an arrest warrant founded on probable cause implicitly carries with it the limited authority to enter a dwelling in which the suspect lives when there is reason to believe the suspect is within." Payton v. New York , 445 U.S. 573, 603, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980). Further, "[i]t is well settled that a search incident to a lawful arrest is a traditional exception to the [search] warrant requirement of the Fourth Amendment." United States v. Robinson , 414 U.S. 218, 224, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973). Thus, "a search may be made of the person of the arrestee by virtue of the lawful arrest. [In addition,] a search may be made of the area within the control of the arrestee." Id . (emphasis omitted).

When a person is arrested inside a residence, the officers may permissibly,

[858 F.3d 149]