isles was the teenager who ran into the building the cork erroneously took traditional notice of pile subsequent conviction and guilty plea and found as a matter of law that it was probable cause justify defendant's entry into plaintiff's home and that led to a directed verdict on all claims except excessive force now is it clear that that's the way of the causation arrow grand because sometimes you know you'll be looking  ante as you should to see if there is probable cause but but something else is in the record that would tend to reinforce the accounts of the police officers they observed something or the something came to their attention  and so i just want to know exactly how confident we can be that the court made that fairly elementary mistake that they did that the court i relying on the guilty plea which of course was not there and in the midst of this wild chase through strikes at chicago the court relied on it and then actually said as a matter of law gave instructions to the jury that the heils was a possession of the drugs that got the drugs and that he pled guilty and that they would have to accept that as as the truth and throughout the trial he said nothing before police officers get to the front door is relevant he said very very clearly he also said very clearly several times during the trial that plaintiffs were trying to assert constitutional rights not understanding that they were asserting their own constitutional right they surely were asserting their own rights not to have the police barge into their house you know no matter my question is you know how important is all of this in the end because we have a situation from the correct standpoint where there are findings that that high ols that the police see trying a couple of houses and bursting into the home of the whites just as i guess michael sr is trying to leave the house he clearly is injured somehow whether by accident or whatever and for all the police know the the residents of the house are in danger you know here's some person who's come barging into their house they don't know whether he's armed or not they don't know anything so they run in afterwards and so i'm trying to focus on what exactly what the whites are that they don't think you should that the police should have entered to begin with i think that's a hard case for you to make maybe they should have stayed there for two hours after they have a high old under control that's different yet and i have to say i'm a little confused about all this g p s discussion because it's not clear to me that there's a time that all six of the officers are out there chasing and if there's somebody able to be behind the wheel and somebody else chasing there's no problem at all with g p s there are several several questions there first of all the it was an afterthought  car slowing to one mile one miles per hour which is essentially stop and there are also gaps of several seconds around those low speed is nobody who says no i was riding around all of them so we got out and we were on foot and back up a minute though because you know looking at the attachments to your brief these s charts certainly made me think that an expert would have been necessary to get these charts properly into evidence and you don't go through that process  like testified he was there the person most knowledgeable in the office of mercy management communications that the city designated in this other case  you are you really saying that you would have given this bunch of data to the jury and had them figure out exactly how this chase unfolded what reisa could have been able to testify to is very basically it was it was not expert he was not drawing conclusions he was only explaining he would have explained it's not an expert i just don't see where you know sort of ordinary human experience gets you to decipher these charts  what he would testify to is that there was only one g p s system that he would have testified as to the relationship between the i wasn't he called in this case me that his testimony from the other case is from a different time you know and maybe you would have gotten him to testify what you're now saying but it's a different time and it's really even more just what does this data reveal it actually when he said that this great island system was the only one that was on the rating in two thousand and eleven so it wouldn't matter that he was testifying in another case he was their employee so he went and he was a police evidence rule seventy two that says if it's your own employee you don't have to qualify them as an expert we are we're saying first of all you don't need an expert here because the t p s is a commonplace system and we' first circuit and the third circuit that say that that that say that you don't have to have it and an expert an expert disclosure would have made any sense and here because the purpose is to give an opportunity the other side to disqualify overt and to retain the bottle experts in and hold additional depositions that he was their employ they were hardly in a position to disqualify him they would not have retained rebuttal witnesses he was always accessible to them to talk for them to talk to and what he would have done is just explain the charts and one thing they do not contest on appeal is that our google maps were somehow that we couldn't do this it was incorrect we said we will bring a computer to court you take the x cornett you take the y coordinate you put it into the program and you get a point and then you put an x coordinate a white corn it in and you get another point that's how you build a map and it's exactly how the police had built their maps rice sic said is in this is other case it would've said in our case if you can take the same x why cornish just as we did put it into a different man ping application and you can you could help the routes but the other thing that the city is not that's in constant motion and also be running down an alley picking up drugs and i'm sure why any of this matters substantively this all goes to the procedural basis for excluding the expert and the g p s evidence but i'm not sure why the details of the chase make a whole lot of difference here because once hiles takes off running in flight from the police when they approach this intersection they have reasonable suspicion choose to stop him and so the only question we have is the legality of the warrantless entry into your client's home and by the time that is conducted they know that he has fled into that home and it's not his home and so they're dealing with at a at the very least a criminal trespass and possibly a  burglary and your client michael white himself said that guy doesn't live here when they approached in that cell so they've got probable cause to entry it's clearly a hot pursuit situation regardless of which path which of the officers took and who was in the car and who was not in the car and who was on foot and setting aside the drugs they've got probable cause to entry based on piles this own entry into a home that's not his the payoff becomes really important because of what you pointed out that the the drugs who were were saying that the drugs were not found it is reality it's set aside the drugs take the drugs completely out of the picture they've got probable cause because ailes has just fled into a home that's not his and they don't know if he is armed and dangerous but they know that this is not his home well we have two residents outside the home with michael white and his sister saying don't break down our door all right but they're also saying he doesn't live here they're saying he doesn't live here you mean michael white it's understandably saying i have a key he said prepared to let the man because he didn't hurry and they don't but i think that's right if we just look at this case as essentially the whites saying the police barged into our house and stayed there too long i'll just totally simplify it all of that chase does nothing but get them to the front door of the house and if we disregard the drugs as judge sykes is suggesting we still have them we still have the police observing high ols barge into the house which probably has people in it there are people standing around so so why don't they have the kind of the hot pursuit and probable cause to going to look for several reasons first of all trussed pass was not ever brought up the trial it was not that matter that the supreme court has said it doesn't make any difference if there's probable cause for something and what we're dealing with is simple trust pass d mr bean or this was never present to the jury in fact the jury was instructed that there is probable cause because of the drugs so the trust p s never came in at the trial we will impose that error we would still have to decide whether it was harmless error whole explanation behind that she was given a blank form to sign she was she was not told that she was going to be signing a criminal charge against him that she did not consent for them to come into the home so does the district court though make a finding of fact about consent i understand that's her position didn't the court find that she did consent but after the court barred us from bringing in any proof that in order to have consent to search the sergeant he asked if there's actual form that has to be signed and the judge would not let us cross examine on that or bring in the form or before your time runs out i want to know whether you are in any way  even if we thought the entry was ok even if we thought the initial search of the room where hiles is hiding out is ok are you making a separate argument about the officers decision to stay in the house for another couple of hours after they have piles under control as part of your claim absolutely and we were barred from calling jill matter at from the city of chicago and she would have said that given the time that the sergeant called in was a least two hours that he was there they searched the house where we claim that there was no this what this wasn't a cursory search this was you know into cabinets and into beds and know if the city concedes that it was error for the district court to allow the plaintiff to challenge the facts came in via the transcripts of hiles lee hearing because i don't think i self you know in this case because all this it's in want that published to the jury was the first two pages of that transcript in the way we're going to see it all so i mean there is some back and forth in the even if we thought the entry itself was justifiable either because of the observed trespasser because of the drugs or some combination of the two observing him trying to get into other places and even if we thought that the search of the room in the back where he's hiding when the police come in is entirely appropriate to make sure he hasn't dropped a gun or more drugs or or whatever i don't see how once he is handcuffed and removed from the house he's not there anymore and hasn't been in the house long enough to go very many places what justifies a two hour search of the house at that point seems to me just because the police walk in doesn't it seems to me that assuming only legal entry clean there are no arguments legal arguments whatsoever to me about the search i didn't see in the way this was litigated in the district court  of separate theory that search was unreasonable and to ration know i'm i'm here on reasonable in scope i understood it to be a claim that it was illegal because the entry of it's illegal right and so we we believe you made in your brief and they say no we've all long been complaining about both the entrance and the such it's all the fourth amendment right and right but then not it's you know the way at least you know we're somehow maybe in the post argument memorandum if if you know you if you would like to pursue that because we did not understand that is separately the reply brief the plaintiffs contend that the city defendants never relied on the probable cause to or trespass as the justification for entering the house said that he lied on  rock wrong first of all is that correct and secondly where in the record will we find the city defendants relying on the trespass to justify entry in who would explain interpret those exhibits to the jury and without this explanation which actually a cold for you know a conclusion an expert on collusion that the car were in constant motion this evidence was meaningless it did not have you know high probative value what about what about their statement never mind whether we have the speeds right but they suggest that there's some streets like that the cars just were never on so at that more modest level down today to show or something  recollection because they were first deposed in february march two thousand and fourteen which is you know more than two and a half years after the incident the trial of this and took place in the afterwards to put the things in perspective whole pay out that's on the g p s and they said that they they never drove there all the officers disclaimed following any of the paths that were in the g p s the defendants never argued that rice sick was an  an expert they said he said he wasn't timely disclosed as a as a lay witness it was the judge who was at trial once the defense counsel says that plaintiffs are trying to show the defendants are perjuring themselves and the judge said basically that's not going to happen it's irrelevant that's not coming in but up until that point she thought that the g p s evidence was miscible he considered it at the motion for summary judgment it wasn't until at trial that the judge himself said she isn't this this man an expert and that was after defense counsel said i think the place to try to show that the defendants are perjuring himself now going to that point i think that's very important because we should have been able to show that these police officers who were lying that they were not telling the truth and they were truthful about where they whether they parked or whether they were driving whether they went up the alley whether they didn't go up the alley their own truthful about that they're probably untruthful by a lot of other things having to do with entering the house and having to do with the search of the house and consent and everything else so why should we have been able to show through g p s that they were not truthful the defendants never explain and i ask for your patience in looking at some of the map and maps and reading our text her description they never explain why these vehicles are continuously moving and how they can reconcile that with six officers saying they parked got out of the car ran three of them going down the only media shows zero miles per hour here and there it shows but it shows your own miles per hour in in one of their round two they were going down a different alley before they pulled up to one of springfield it also if you it goes the there was a time when they were at thomas and polanski goes from one to four to i think twenty six miles an hour but it's also changing direction radically and so what they were doing there as they turned down thomas did a quick u turn and went up polanski there was a time even if they were stunt men they could have jumped out of the car and done any of this but it also