Is a warrantless arrest, in the absence of exigent circumstances, by physical force, for a misdemeanor, in the entrance to the curtilage of the suspect's home an unreasonable seizure?

QUESTION PRESENTED Is it clearly established that a warrantless arrest, in the absence of exigent circumstances, by physical force, for a misdemeanor, in the entrance to the curtilage of the suspect’s home is an unreasonable seizure, or could a reasonable officer still believe that the “doorway exception” of United States v. Santana, 427 U.S. 38 (1976), allows for such an arrest? u RELATED CASES Nicholas Yarofalchuw v. John Cabrera and Danny Fitial, No. 1:22-cv-01, District Court for the Northern Mariana Islands. Judgment entered February 2, 2023. Nicholas Yarofalchuw v. John Cabrera and Danny Fitial, No. 23-15279, United States Court of Appeals for the Ninth Circuit. Judgment entered March 8, 2024. Nicholas Yarofalchuw v. Commonwealth of the Northern Mariana Islands, No. 22-0230-CV, Superior Court of the Commonwealth of the Northern Mariana Islands. Dismissed without prejudice by stipulation December 29, 2022. Nicholas Yarofalchuw v. Commonwealth of the Northern Mariana Islands, No. 23-0067-CV, Superior Court of the Commonwealth of the Northern Mariana Islands. Pending.