In what circumstances will a police officer be permitted to search a defendant's purse on suspicion of drug dealing?

In Remers v. Superior Court, supra, 2 Cal.3d 659, 87 Cal.Rptr. 202, 470 P.2d 11, the arresting officer arrested and searched the defendant's purse when he heard from other [59 Cal.App.4th 1554] officers the defendant had been selling dangerous drugs before. The officer, however, did not know whether the basis of the information given him by other officers came from an informer or some other officer who actually observed the defendant make a sale of drugs. The court ruled the arresting officer lacked probable cause to search the defendant's purse because the prosecution failed to show the basis for the former officer's information. To explain its ruling, the court stated "the absence of such a requirement would allow a police officer to manufacture reasonable grounds to arrest while circumventing the necessity of pointing to 'specific and articulable facts' justifying his suspicions." (At p. 667, 87 Cal.Rptr. 202, 470 P.2d 11, quoting from Terry v. Ohio, supra, 392 U.S. 1, 21, 88 S.Ct. 1868, 1879, 20 L.Ed.2d 889.)