California, United States of America
The following excerpt is from People v. Thompson, 124 Cal.App.4th 96, 21 Cal.Rptr.3d 221 (Cal. App. 2004):
Relying on People v. Hampton (1985) 164 Cal.App.3d 27, 209 Cal.Rptr. 905, the majority of the appellate division ruled that the warrantless entry did not violate the Fourth Amendment. The court reasoned that Orvos, who had probable cause to make a citizen's arrest, somehow authorized the officers' entry into the residence: "[T]he exigencies of preventing defendant from fleeing and possibly again driving while intoxicated, and of preserving evidence of his blood alcohol content, along with the physical presence of the complaining private citizen, ... all combined to justify the officers' entry to follow and apprehend defendant...."
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