The following excerpt is from U.S. v. Winsor, 846 F.2d 1569 (9th Cir. 1988):
Winsor argues that the police effected a nonconsensual search of the room when they knocked on the door and commanded that it be opened under claim of lawful authority. He argues further that under Arizona v. Hicks, --- U.S. ----, 107 S.Ct. 1149, 94 L.Ed.2d 347 (1987), the search of his one-room residence could not be based on a level of suspicion less than probable cause.
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