¶ 1. This is a review of a published decision of the court of appeals1 that affirmed a judgment of conviction entered upon a guilty plea by the Milwaukee County Circuit Court, Joseph R. Wall, Judge. Acting upon an anonymous informant's tip and what they believed to be an outstanding felony arrest warrant, police officers forcibly entered and subsequently searched the apartment of Terion Lamar Robinson (Robinson). Following the circuit court's denial of his motion to suppress, Robinson pled guilty to one count of possession with intent to deliver tetrahydrocannabinols (THC), 200 grams or less, in violation of Wis. Stat. § 961.41(lm)(h)l (2005-06).2 On appeal, Robinson argues that the officers' warrantless entry into his apartment and subse*309quent search violated his constitutional rights against unreasonable searches and seizures. We disagree and therefore affirm the court of appeals decision.
¶ 2. The dispositive issue in this case is whether the police officers' warrantless entry into Robinson's apartment and subsequent search was supported by probable cause and justified by exigent circumstances when the officers corroborated three of the four details relayed by an anonymous informant, knocked and announced their presence, and immediately heard footsteps running from the door.
¶ 3. Assuming without deciding that the commitment order for unpaid fines did not constitute an arrest warrant and therefore was insufficient to permit the police officers' lawful entry into Robinson's apartment, we conclude that the warrantless entry was nevertheless reasonable because it was supported by probable cause and justified by exigent circumstances. First, we determine that the police officers' warrantless entry into Robinson's apartment was supported by probable cause. Because the officers corroborated each of the three preliminary details provided by the anonymous informant, it was reasonable for the officers to then *310believe, as the informant had alleged, that evidence of illegal drug activity would probably be found in Robinson's apartment. Second, we conclude that the police officers' warrantless entry into Robinson's apartment was justified by exigent circumstances. Once Robinson was aware of the officers' presence outside his door and footsteps were immediately heard running from the door, the officers reasonably believed that Robinson would destroy evidence of his illegal drug activity. Finally, we conclude that once inside the apartment, the officers lawfully seized the evidence in plain view and arrested Robinson.
I. FACTUAL BACKGROUND AND PROCEDURAL POSTURE
¶ 4. On November 6, 2006, an anonymous citizen walked into Milwaukee's District Five police station and informed Officer Wesam Yaghnam (Officer Yaghnam) that a man by the name of Terion Robinson was selling marijuana out of his apartment. The citizen provided Officer Yaghnam with Robinson's complete address, 7233 North 38th Street in Milwaukee, Apartment 8, in addition to Robinson's cell phone number.
¶ 5. Officer Yaghnam then conducted a warrant check on the Crime Information Bureau (CIB) and the National Crime Information Center (NCIC) databases.3 According to Officer Yaghnam's testimony at the suppression hearing, his search revealed that Robinson *311"had two open warrants," one for a "family offense" and another for "the possession of [or] delivery of a controlled substance." Listed on the screen were the names of the warrants, what the warrants were for, and their case numbers. The warrant for possession or delivery of a controlled substance had a felony case number.
¶ 6. Consistent with his usual practice, Officer Yaghnam did not pull the warrants and testified that he does not always have the capability of doing so. Instead, "[a]ll [the officers] do is [] run on the system. If it comes back with a warrant, then that is in good faith, and that is how [they] arrest."
¶ 7. After conducting the warrant check, Officer Yaghnam and several other officers4 went to the address identified by the anonymous informant as Robinson's apartment. The officers did not seek a search warrant, as they were intending to conduct a "knock and talk."5 The officers were let into the building by another resident. Some officers, including Officer *312Yaghnam, proceeded upstairs to Apartment 8, while others remained outside to secure the exits.
¶ 8. According to Officer Yaghnam, the officers knocked on the door to Apartment 8 several times with no answer. They knocked again and heard movement inside the apartment, leading them to believe that somebody was inside. At that point, Officer Yaghnam called the cell phone number provided by the anonymous informant. A phone rang on the other side of the door, but nobody answered. Officer Yaghnam described the succeeding events as follows:
Q [Attorney Merten, on behalf of the State]: What happened next?
A [Officer Yaghnam]: I then knocked on the door again, and then a male voice replied, "Who is it?" I then replied, "Terion?" And he stated, "Yes," actually, ’Yeah." Then I identified myself as, "The Milwaukee police department. You need to open the door." And that is when I heard footsteps running from the door.
Q: And when you said you heard footsteps running from the door, was that — how quickly after the fact that you identified yourself as a Milwaukee Police Department officer did you hear that?
*313A: Immediately.
Q: And when you heard those footsteps, what did you do then?
A: Then, fearing for the safety of possibly him destroying evidence or escaping, we then forced entry into the building, into the apartment.
Q: How soon did you force entry after you heard those footsteps?
A: Immediately.
Q: And how did you force entry?
A: By kicking open the door.
¶ 9. After Officer Yaghnam kicked open the door, he and the other officers proceeded into the apartment. Upon entering the residence, Officer Yaghnam identified a "pretty strong" odor of burnt marijuana. He described the apartment's layout as an "open concept." Immediately to the right of the door was a kitchen, which opened up to a dining room. Robinson was standing in the dining room. The dining room flowed into a living room, where the officers found a female later identified as Roxanne Reindl (Reindl). The apartment had a balcony exit, accessible by a sliding door located between the dining room and living room. Officer Yaghnam observed loose marijuana on a coffee table in the living room and several individual bags of marijuana inside an open cooler next to the couch.
¶ 10. Officer Yaghnam arrested Robinson, citing as the basis Robinson's "open warrants."6 He then searched Robinson's person and recovered "a large *314amount of currency"7 and a cell phone. The cell phone's number matched the one Officer Yaghnam previously dialed. The officers also seized two digital scales and a box of sandwich baggies; one of the scales and the baggies were taken from the kitchen counter.8
¶ 11. On November 8, 2006, Robinson was charged with one count of possession with intent to deliver THC, more than 200 grams but not more than 1,000 grams, in violation of Wis. Stat. § 961.41(1m)(h)2. On January 7, 2007, Robinson moved to suppress all evidence obtained from his apartment on the grounds that it was the fruit of an unlawful entry.
¶ 12. On January 10, 2007, the circuit court conducted a hearing on Robinson's motion to suppress, at which Robinson largely corroborated Officer Yaghnam's testimony. Robinson recalled hearing knocks on his apartment door9 on November 6, 2006, immediately followed by his cell phone ringing. He testified that he silenced his ringer and then went to the door to look out the peep hole, but the peep hole was covered. When he asked who was there, someone responded, "Milwaukee Police Department. Open up." According to Robinson, he then replied, " 'No, thank you,' and walked away from the door, and they started kicking in the door." He denied running from the door and stated that he was not wearing shoes at the time.
*315¶ 13. Robinson also denied smoking marijuana that day but testified that Reindl was. He admitted that a strong odor of marijuana was in the air in his apartment and that marijuana was on the coffee table. When asked if he was aware that marijuana was also in the cooler, he responded that he was not: "I seen the weed that was on the table. [The cooler] couldn't have been — [i]t had to have been out of sight."
¶ 14. Reindl also testified at the suppression hearing. She recalled visiting Robinson at his apartment on November 6, 2006, and smoking "[a] little bit" of marijuana.
¶ 15. At the close of the suppression hearing, it came to light that what Officer Yaghnam thought was an open felony warrant for possession or delivery of a controlled substance was actually a commitment order for unpaid fines. In particular, on September 29, 2006, the Milwaukee County Circuit Court issued a commitment order for unpaid fines stemming from Robinson's 1998 conviction for manufacturing or delivering THC. According to court records, on December 18, 1998, then-circuit court Judge Kitty K. Brennan10 sentenced Robinson to 12 months imprisonment and ordered him to "pay a fine in the amount of $500.00 plus all costs and surcharges at $50.00 a month, starting 3/1/99 and thereafter on the first of every month or serve 60 days STRAIGHT TIME in the House of Correction consecutive to any other sentence." The commitment order was signed by an assistant to the Clerk of Circuit Court and *316ordered that "any law enforcement officer arrest and detain Terion L[.] Robinson Jr[.] in custody for 60 days or until $1026.50 is paid."
¶ 16. On March 14, 2007, the circuit court issued an oral decision denying Robinson's motion to suppress. The court adopted Officer Yaghnam's testimony as its findings of fact, noting that "[ejven Terion Robinson's version of all of this [wa]s not that much different than the police[’s]." In particular, the court made a threshold finding that the officers, relying on the CIB and NCIC databases, believed that Robinson was subject to an outstanding felony arrest warrant for manufacturing or delivering marijuana. Citing State v. Collins, 122 Wis. 2d 320, 326, 363 N.W.2d 229 (1984), the circuit court concluded that the evidence should not be suppressed because the officers believed they had a valid arrest warrant which authorized entry into Robinson's apartment.
¶ 17. As alternative grounds for denying Robinson's motion to suppress, the circuit court applied State v. Hughes, 2000 WI 24, 233 Wis. 2d 280, 607 N.W.2d 621, and determined that the officers' otherwise warrantless entry into Robinson's apartment was supported by probable cause and justified by exigent circumstances. The court concluded that the officers had probable cause to believe that the apartment contained evidence of a crime because they confirmed information relayed by the anonymous informant, specifically Robinson's apartment number and his cell phone number. In addition, the court believed Officer Yaghnam's testimony that he heard footsteps running from the door and consequently feared the destruction of evidence.
*317¶ 18. Following the circuit court's denial of his motion to suppress, Robinson pled guilty to a reduced charge of one count of possession with intent to deliver THC, 200 grams or less, and the circuit court entered judgment of conviction.
¶ 19. Robinson appealed his conviction and the order denying his motion to suppress. On June 30, 2009, the court of appeals affirmed. State v. Robinson, 2009 WI App 97, 320 Wis. 2d 689, 770 N.W.2d 721. Assuming without deciding that the commitment order was insufficient to permit the officers' lawful entry into Robinson's apartment, the court of appeals concluded that the evidence derived from the warrantless entry and search was nevertheless admissible under the good faith exception to the exclusionary rule. Id., ¶ 1 (citing United States v. Leon, 468 U.S. 897 (1984); State v. Eason, 2001 WI 98, 245 Wis. 2d 206, 629 N.W.2d 625). The court determined that Officer Yaghnam had a good faith belief that what he discovered on the CIB and NCIC databases was an open felony warrant for Robinson's arrest. Id., ¶ 11. Recognizing that police reliance on those databases is considered standard operating procedure, the court declined to suppress evidence obtained as a result: " 'Suppressing evidence obtained in a situation where a reasonable officer would believe an arrest warrant existed would not help to deter misconduct by arresting officers, because there is no misconduct to deter.'" Id. (quoting Collins, 122 Wis. 2d at 326).
¶ 20. In addition, like the circuit court, the court of appeals determined that the officers' warrantless entry was alternatively justified by exigent circumstances: "Robinson was in the identified apartment and had the cell phone number given by the informant. When the police heard footsteps moving away from the *318door suggesting a possible escape attempt or a destruction of evidence, exigent circumstances were created permitting the officers to kick in the door." Id., ¶ 17.
¶ 21. Robinson petitioned this court for review, which we granted on November 12, 2009. We now affirm.
II. STANDARD OF REVIEW
¶ 22. Our review of an order granting or denying a motion to suppress evidence presents a question of constitutional fact. Hughes, 233 Wis. 2d 280, ¶ 15. When presented with a question of constitutional fact, this court engages in a two-step inquiry. State v. Pallone, 2000 WI 77, ¶ 27, 236 Wis. 2d 162, 613 N.W.2d 568; Hughes, 233 Wis. 2d 280, ¶ 15. First, we review the circuit court's findings of historical fact under a deferential standard, upholding them unless they are clearly erroneous. See State v. Popke, 2009 WI 37, ¶ 10, 317 Wis. 2d 118, 765 N.W.2d 569; Pallone, 236 Wis. 2d 162, ¶ 27; Hughes, 233 Wis. 2d 280, ¶ 15. Second, we independently apply constitutional principles to those facts. Pallone, 236 Wis. 2d 162, ¶ 27; Hughes, 233 Wis. 2d 280, ¶ 15; State v. Limon, 2008 WI App 77, ¶ 12, 312 Wis. 2d 174, 751 N.W.2d 877.
III. ANALYSIS
¶ 23. In this case, we assume without deciding that the commitment order for unpaid fines did not constitute an arrest warrant and therefore was insufficient to permit the police officers' lawful entry into Robinson's apartment. We need not determine whether the good faith exception to the exclusionary rule applies *319because we conclude that the officers’ warrantless entry and subsequent search was justified on the more narrow grounds of probable cause and exigent circumstances.
¶ 24. The Fourth Amendment to the United States Constitution and Article I, Section 11 of the Wisconsin Constitution protect ”[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures." U.S. Const. amend. IV; Wis. Const, art. 1, § 11.11 Because physical entry of the home is deemed " 'the chief evil against which the wording of the Fourth Amendment is directed,'" Payton v. New York, 445 U.S. 573, 585 *320(1980) (quoting United States v. U.S. Dist. Court for E. Dist. of Mich., S. Div., 407 U.S. 297, 313 (1972)), warrantless searches of homes are presumptively unreasonable, Welsh v. Wisconsin, 466 U.S. 740, 749 (1984); Payton, 445 U.S. at 586; Pallone, 236 Wis. 2d 162, ¶¶ 29, 59; Hughes, 233 Wis. 2d 280, ¶ 17. However, the doctrine of exigent circumstances is one of the well-recognized exceptions to the warrant requirement. See Payton, 445 U.S. at 590; Hughes, 233 Wis. 2d 280, ¶ 17; State v. Smith, 131 Wis. 2d 220, 228, 388 N.W.2d 601 (1986). The exception recognizes that in special circumstances, when there is an urgent need coupled with insufficient time to obtain a warrant, "it would be unrealistic and contrary to public policy to bar law enforcement officials at the doorstep." Smith, 131 Wis. 2d at 228. In such instances, an individual's substantial right to privacy in his or her home must give way to the compelling public interest in effective law enforcement. See Hughes, 233 Wis. 2d 280, ¶ 16; Smith, 131 Wis. 2d at 228. The government bears the burden of showing that the warrantless entry was both supported by probable cause and justified by exigent circumstances. See Welsh, 466 U.S. at 750; Pallone, 236 Wis. 2d 162, ¶ 29; Hughes, 233 Wis. 2d 280, ¶ 17; Smith, 131 Wis. 2d at 228.
¶ 25. In this case, we conclude that the State has satisfied its burden of demonstrating that the police officers' warrantless entry into Robinson's apartment was both supported by probable cause and justified by exigent circumstances. We will analyze each requirement in turn.
A. Probable Cause
¶ 26. The Fourth Amendment to the U.S. Constitution and Article I, Section 11 of the Wisconsin Con*321stitution "require^ probable cause to support every search or seizure in order to 'safeguard the privacy and security of individuals against arbitraiy invasions by government officials.'" Hughes, 233 Wis. 2d 280, ¶ 19 (quoting State v. DeSmidt, 155 Wis. 2d 119, 130, 454 N.W.2d 780 (1990)). In the search context, probable cause requires a" 'fair probability' that contraband or evidence of a crime will be found in a particular place." Hughes, 233 Wis. 2d 280, ¶ 21 (quoting Illinois v. Gates, 462 U.S. 213, 238 (1983)); see also State v. Carroll, 2010 WI 8, ¶ 28, 322 Wis. 2d 299, 778 N.W.2d 1. We evaluate the existence of probable cause objectively, concerned with whether law enforcement acted reasonably. See Illinois v. Rodriguez, 497 U.S. 177, 185 (1990) ("[I]n order to satisfy the 'reasonableness' requirement of the Fourth Amendment, what is generally demanded of the many factual determinations that must regularly be made by agents of the government — whether the magistrate issuing a warrant, the police officer executing a warrant, or the police officer conducting a search or seizure under one of the exceptions to the warrant requirement — is not that they always be correct, but that they always be reasonable."); Gates, 462 U.S. at 231 (" 'In dealing with probable cause,... as the very name implies, we deal with probabilities. These are not technical; they are the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act.'" (quoting Brinegar v. United States, 338 U.S. 160, 175 (1949))); Hughes, 233 Wis. 2d 280, ¶ 23. In other words, in this case, we must determine whether it was reasonable for Officer Yaghnam and the other police officers to believe that evidence of illegal drug activity would probably be found in Apartment 8. See Hughes, 233 Wis. 2d 280, ¶ 23. We conclude that it was.
*322¶ 27. The officers were acting upon an anonymous informant's tip that Robinson was selling marijuana out of his apartment. Considered within the totality of the circumstances, the value and reliability of an informant's tip "may usefully illuminate the commonsense, practical question whether there is 'probable cause' to believe that contraband or evidence is located in a particular place." Gates, 462 U.S. at 230. The U.S. Supreme Court has recognized the particular value of law enforcement's corroboration of details of an informant's tip. Id. at 241. " 'Because an informant is right about some things, he is more probably right about other facts.'" Id. at 244 (quoting Spinelli v. United States, 393 U.S. 410, 427 (1969) (White, J., concurring)). That is, police corroboration of innocent, although significant, details of an informant's tip lend reliability to the informant's allegations of criminal activity. See State v. Williams, 2001 WI 21, ¶¶ 39-40, 241 Wis. 2d 631, 623 N.W.2d 106. For purposes of making a practical, common-sense determination of probable cause, that is sufficient. Gates, 462 U.S. at 244-45 ("It is enough, for purposes of assessing probable cause, that 'corroboration through other sources of information reduced the chances of a reckless or prevaricating tale,' thus providing 'a substantial basis for crediting the hearsay.'" (quoting Jones v. United States, 362 U.S. 257, 271 (1960))).
¶ 28. In this case, the officers corroborated three of the four details relayed by the anonymous informant. According to Officer Yaghnam's testimony,12 the infor*323mant provided the following four details: (1) Someone named Terion Robinson, (2) who lived in Apartment 8 at 7233 North 38th Street in Milwaukee (3) with cell phone number [], (4) was selling marijuana out of his apartment. While the informant failed to explain how he came to know of the inside information, the specificity of his information and the fact that he personally walked into the police station supported his credibility. Indeed, the informant was "anonymous" only to the extent that he was nameless. He jeopardized his anonymity by approaching Officer Yaghnam in person. See Limon, 312 Wis. 2d 174, ¶ 18. "Risking one's identification intimates that, more likely than not, the informant is a genuinely concerned citizen as opposed to a fallacious prankster." Williams, 241 Wis. 2d 631, ¶ 35.
¶ 29. In the midst of their "knock and talk," the officers corroborated each of the three preliminary details provided by the anonymous informant: Robinson's name, his address, and his cell phone number. According to Officer Yaghnam's testimony, after he knocked on the door to Apartment 8, a male voice questioned from inside, "Who is it?" Officer Yaghnam replied, "Terion?" The male voice then answered, "Yeah." When Officer Yaghnam dialed the cell phone number identified by the informant as Robinson's, a phone immediately rang on the other side of the door. It was therefore reasonable for the officers to believe, just as the informant had said, that Terion Robinson resided in Apartment 8. The officers' corroboration of innocent, although significant, details of the informant's tip lent *324reliability to the informant's allegation that Robinson was selling marijuana out of his apartment. See Williams, 241 Wis. 2d 631, ¶ 40. The officers may not have corroborated the substantive allegation of criminal activity, but that is not what probable cause demands:
[P]robable cause requires only a probability or substantial chance of criminal activity, not an actual showing of such activity. By hypothesis, therefore, innocent behavior frequently will provide the basis for a showing of probable cause; to require otherwise would be to sub silentio impose a drastically more rigorous definition of probable cause than the security of our citizens demands. .. .
Gates, 462 U.S. at 243 n.13. Moreover, regardless of whether or not the commitment order constituted an arrest warrant, a question which we do not decide, it remains that the officers believed that Robinson was subject to an outstanding felony arrest warrant for manufacturing or delivering marijuana. In the least, the officers were cognizant of the fact that Robinson was previously charged with illegal drug activity. That knowledge further lent reliability to the informant's allegation that Robinson was selling marijuana. Because the officers corroborated each of the three preliminary details provided by the anonymous informant, we conclude that it was reasonable for the officers to then believe, as the informant had alleged, that evidence of illegal drug activity would probably be found in Apartment 8. Accordingly, the State has satisfied its burden of demonstrating that the police officers' warrantless entry into Robinson's apartment was supported by probable cause. We now turn to the State's requisite showing of exigent circumstances.
*325B. Exigent Circumstances
¶ 30. Consistent with the U.S. Supreme Court, see, e.g., Brigham City, Utah v. Stuart, 547 U.S. 398, 403 (2006); Georgia v. Randolph, 547 U.S. 103, 116 n.6. (2006); Welsh, 466 U.S. at 750, this court has recognized four circumstances which, when measured against the time required to procure a warrant, constitute exigent circumstances that justify a warrantless entry: (1) an arrest made in "hot pursuit," (2) a threat to the safety of the suspect or others, (3) a risk that evidence will be destroyed, and (4) a likelihood that the suspect will flee. Hughes, 233 Wis. 2d 280, ¶ 25; Smith, 131 Wis. 2d at 229. Like our analysis of probable cause, the test for determining the existence of exigent circumstances is an objective one. See Brigham City, 547 U.S. at 403-04; Smith, 131 Wis. 2d at 230. We must determine whether the police officers under the circumstances known to them at the time reasonably believed that a delay in procuring a warrant would gravely endanger safety, risk the destruction of evidence, or enhance the likelihood that the suspect will escape. Smith, 131 Wis. 2d at 230.
¶ 31. In this case, we conclude that the police officers' warrantless entry into Robinson's apartment was justified by exigent circumstances because the officers reasonably believed that a delay in procuring a warrant would risk the destruction of evidence. Officer Yaghnam testified that after knocking on the door to Apartment 8 and identifying himself as the Milwaukee Police Department, he "heard footsteps running from the door." Because he "fear[ed] for the safety of possibly *326[Robinson] destroying evidence,"13 he forced entry into the apartment by kicking open the door. Once Robinson was aware of the officers' presence outside his door and footsteps were immediately heard running from the door, it was certainly reasonable for the officers to assume that Robinson would destroy evidence of his illegal drug activity. Drugs like marijuana are easily and quickly destroyed. See Hughes, 233 Wis. 2d 280, ¶ 26; State v. Henderson, 2001 WI 97, ¶ 38, 245 Wis. 2d 345, 629 N.W.2d 613. Under all the circumstances of this case, Robinson had every incentive to intentionally destroy evidence of the marijuana in order to avoid its discovery. See Hughes, 233 Wis. 2d 280, ¶ 27. "Had the officers stayed outside and called for a warrant, the evidence very likely would have been lost." Id.
¶ 32. Robinson argues that to the extent the officers' knock and announcement led to the running footsteps, the officers manufactured the exigent circumstances and therefore cannot rely on them. This court has recognized that police officers may not benefit from exigent circumstances that they themselves create. Id., ¶ 28 n.7. However, we disagree with Robinson that the officers impermissibly created the exigent circumstances merely by knocking on his door and announcing their presence. "[W]hen law enforcement agents act in an entirely lawful manner, they do not impermissibly create exigent circumstances." United *327States v. MacDonald, 916 F.2d 766, 772 (2d Cir. 1990). By knocking on Robinson's door and announcing themselves as the Milwaukee Police Department, an announcement which in fact was invited by Robinson's question of "Who is it?", the officers were conducting themselves in an utterly appropriate and lawful manner. See United States v. Collins, 510 F.3d 697, 700 (7th Cir. 2007) ("[T]here is no legal requirement of obtaining a warrant to knock on someone's door.").14 Simply because Robinson chose to respond to the officers' lawful conduct by running from the door, thereby leading the officers to believe that he would destroy evidence, does not mean that we ought to overlook the exigent circumstances. See MacDonald, 916 F.2d at 771 *328("Exigent circumstances are not to be disregarded simply because the suspects chose to respond to the agents' lawful conduct by attempting to escape, destroy evidence, or engage in any other unlawful activity."). It was not the officers' knock and announcement that created the exigent circumstances. To hold otherwise would defy the very standard of reasonableness considered to be the "ultimate touchstone of the Fourth Amendment." See Brigham City, 547 U.S. at 403. Rather, Robinson's choice to run from the door created the exigent circumstances that justified the officers' warrantless entry.
¶ 33. To complete our analysis, we conclude that once inside the apartment, the officers lawfully seized the evidence in plain view and arrested Robinson. Once inside, the officers identified a strong odor of burnt marijuana and observed loose marijuana in plain view on the coffee table, both facts that Robinson himself conceded. Officer Yaghnam also testified that a digital scale and box of sandwich baggies were in plain view on the kitchen counter. The officers were well within their rights to seize the marijuana, digital scale, and sandwich baggies in plain view. See Harris v. United States, 390 U.S. 234, 236 (1968) ("It has long been settled that objects falling in the plain view of an officer who has a right to be in the position to have that view are subject to seizure and may be introduced in evidence."); State v. Johnston, 184 Wis. 2d 794, 809, 518 N.W.2d 759 (1994). Moreover, Officer Yaghnam was entitled to arrest Robinson because the evidence in plain view gave him probable cause to believe that Robinson had committed a crime. See United States v. Hensley, 469 U.S. 221, 235 (1985); Johnston, 184 Wis. 2d at 809. Finally, Officer Yaghnam lawfully searched Robinson's person incident to arrest and seized the large amount of currency and *329Robinson's cell phone. See Wis. Stat. § 968.11 (2007-08); Chimel v. California, 395 U.S. 752, 763 (1969).
IV CONCLUSION
¶ 34. Assuming without deciding that the commitment order for unpaid fines did not constitute an arrest warrant and therefore was insufficient to permit the police officers' lawful entry into Robinson's apartment, we conclude that the warrantless entry was nevertheless reasonable because it was supported by probable cause and justified by exigent circumstances. First, we determine that the police officers' warrantless entry into Robinson's apartment was supported by probable cause. Because the officers corroborated each of the three preliminary details provided by the anonymous informant, it was reasonable for the officers to then believe, as the informant had alleged, that evidence of illegal drug activity would probably be found in Robinson's apartment. Second, we conclude that the police officers' warrantless entry into Robinson's apartment was justified by exigent circumstances. Once Robinson was aware of the officers' presence outside his door and footsteps were immediately heard running from the door, the officers reasonably believed that Robinson would destroy evidence of his illegal drug activity. Finally, we conclude that once inside the apartment, the officers lawfully seized the evidence in plain view and arrested Robinson.
By the Court. — The decision of the court of appeals is affirmed.
State v. Robinson, 2009 WI App 97, 320 Wis. 2d 689, 770 N.W.2d 721.
All subsequent references to the Wisconsin Statutes are to the 2005-06 version unless otherwise indicated.
Wisconsin Stat. § 961.41(1m) "Possession with intent to manufacture, distribute or deliver" provides in relevant part:
Except as authorized by this chapter, it is unlawful for any person to possess, with intent to manufacture, distribute or deliver, a controlled substance or a controlled substance analog. Intent under this subsection may be demonstrated by, without limitation because of enumeration, evidence of the quantity and monetary value of the substances possessed, the possession of *309manufacturing implements or paraphernalia, and the activities or statements of the person in possession of the controlled substance or a controlled substance analog prior to and after the alleged violation. Any person who violates this subsection is subject to the following penalties:
(h) Tetrahydrocannabinols. If a person violates this subsection with respect to tetrahydrocannabinols, included under s. 961.14(4)(t), or a controlled substance analog of tetrahydrocannabinols, and the amount possessed, with intent to manufacture, distribute, or deliver, is:
1. Two hundred grams or less, or 4 or fewer plants containing tetrahydrocannabinols, the person is guilty of a Class I felony.
The CIB operates and manages a law enforcement message switch and network system that provides criminal justice employees with a wide variety of information, including "wants and warrants, driver license and vehicle registration information, criminal histories, protection order and injunction files, sex offender and corrections information, stolen property, miss*311ing persons and more." Wisconsin Department of Justice, Law Enforcement Services: CIB, http://www.doj.state.wi.us/dles/cib/ (last visited July 6, 2010).
The NCIC, described by the Federal Bureau of Investigation (FBI) as "the lifeline of law enforcement," is an electronic clearinghouse of crime data that enables criminal justice agencies nationwide to "apprehend fugitives, locate missing persons, recover stolen property, and identify terrorists." FBI, NCIC: The National Crime Information Center, http://www.fbi.gov/hq/ cjisd/ncic.htm (last visited July 6, 2010).
According to Officer Yaghnam's testimony, he and his partner were joined by five other squads for a total of eight officers.
The Seventh Circuit Court of Appeals explained the "knock and talk" technique in United States v. Johnson, 170 F.3d 708, 711 (7th Cir. 1999):
*312[I]n a "knock and talk," the police approach a house or apartment in which they suspect drug dealing is occurring. They listen outside the door for a brief period of time, and then they knock on the door and attempt to persuade whoever answers to give them permission to enter. If consent is forthcoming, they enter and interview the occupants of the place; if it is not, they try to see from their vantage point at the door whether drug paraphernalia or contraband is in plain view. If it is, then they malee a warrantless entry. As this description makes plain, the "knock and talk" procedure typically does not involve the prior issuance of a warrant.
See also State v. Phillips, 2009 WI App 179, ¶ 11 n.6, 322 Wis. 2d 576, 778 N.W.2d 157.
The officers also arrested Reindl. Her arrest is not at issue in this case.
According to the complaint, Robinson was in possession of $1,800.
Officer Yaghnam acknowledged that the second scale was not in plain view and was instead located in a closet adjacent to Robinson's bedroom. The circuit court deemed that scale inadmissible.
Robinson initially denied residing at the apartment, testifying that it was not his residence but instead his girlfriend's. He has since abandoned that argument.
Prior to oral argument before this court, the State filed a letter informing us that Judge Brennan was a member of the court of appeals panel that decided this case. The matter was not brought to the court of appeals' attention, and neither Robinson nor the State has briefed or filed a motion on the issue before this court. We therefore will not address it further.
The Fourth Amendment to the United States Constitution provides in full:
The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.
Article I, Section 11 of the Wisconsin Constitution similarly states:
The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures shall not be violated; and no warrant shall issue but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched and the persons or things to be seized.
As a general rule, we historically interpret the search and seizure provision of our state's constitution consistent with the United States Supreme Court's interpretation of the Fourth Amendment. See State v. Pallone, 2000 WI 77, ¶ 28, 236 Wis. 2d 162, 613 N.W.2d 568; State v. Hughes, 2000 WI 24, ¶ 17 n.6, 233 Wis. 2d 280, 607 N.W.2d 621; State v. DeSmidt, 155 Wis. 2d 119, 130, 454 N.W.2d 780 (1990); State v. Limon, 2008 WI App 77, ¶ 11 n.5, 312 Wis. 2d 174, 751 N.W.2d 877.
The circuit court adopted Officer Yaghnam's testimony as its findings of fact. We uphold those findings as they are not *323clearly erroneous. See Pallone, 236 Wis. 2d 162, ¶ 27; Hughes, 233 Wis. 2d 280, ¶ 15. This is particularly true because, as the circuit court pointed out, Robinson himself confirmed much of Officer Yaghnam's testimony.
Officer Yaghnam also testified that he feared Robinson's escape. Our conclusion that the officers reasonably believed that a delay in procuring a warrant would risk the destruction of evidence is alone sufficient to give rise to exigency. We therefore need not decide whether the officers reasonably believed that a delay in procuring a warrant would enhance the likelihood of Robinson's escape.
Relying instead on United States v. Ellis, 499 F.3d 686 (7th Cir. 2007), see dissent, ¶¶ 72-77, the dissent makes no mention of United States v. Collins, 510 F.3d 697 (7th Cir. 2007), the more recent Seventh Circuit decision in which the court favorably cited United States v. MacDonald, 916 F.2d 766, 772 (2d Cir. 1990). Collins, 510 F.3d at 700. In Collins, the Seventh Circuit distinguished its set of facts, where there was "no evidence that the officers heard the sound of running feet," id. at 699, from those in MacDonald, in which the law enforcement agents heard the sound of shuffling feet from inside the apartment. Id. at 700 (citing MacDonald, 916 F.2d at 771). The Seventh Circuit in Collins agreed that suppression of the evidence would not be justified under the facts of MacDonald. Id.
Moreover, in its discussion of the Seventh Circuit's earlier decision in Ellis, see dissent, ¶¶ 72-77, the dissent leaves out the key facts that distinguish the complicated analysis in Ellis from the facts of this case. Among other things, in Ellis, the police officer who kicked in the side door made no showing to differentiate the movement he heard inside the home from the reasonable type of movement that could be found in any home following a knock at the door. 499 F.3d at 691.