The following excerpt is from U.S. v. Underwood, 717 F.2d 482 (9th Cir. 1983):
In Payton v. New York, 445 U.S. 573 [100 S.Ct. 1371, 63 L.Ed.2d 639], we held that police officers may not enter a private residence to make a routine felony arrest without first obtaining a warrant. In that case we rejected the suggestion that only a search warrant could adequately protect the privacy interests at stake, noting that the distinction between a search warrant and an arrest warrant was far less significant than the interposition of the magistrate's determination of probable cause between the zealous officer and the citizen:
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