While lying in his bed, Quaempts opened the front door to his small trailer in response to a knock by tribal police officers. Officers arrested him without a warrant for a sexual assault. The district court granted his motion to suppress because the police required a warrant prior to arresting appellant in his home. On appeal, the government argued that when appellant opened the door, he waived any expectation of privacy in his home. The appellate court rejected the government’s argument, holding that a warrant was required to arrest appellant in his own home. The fact that the officers didn’t enter the home did not matter – it is the location of the arrested person which determines whether an arrest is in the home. Reaching over from his bed and opening his door did not waive appellant’s expectation of privacy guaranteed by the Fourth Amendment.