Can police enter an apartment hallway without a warrant?

In People v. Seals, 263 Cal.App.2d 575, 577, 69 Cal.Rptr. 861, this statewide court held that officers can constitutionally enter apartment hallways and other common areas without a warrant or express permission from particular tenants. In the present case, however, officers gained entry to the hallway through a locked door. Appellant argues that in doing so the police committed a trespass in violation of his constitutional rights of privacy and freedom from unreasonable search and seizure.