The following excerpt is from Lowry v. City of San Diego, 858 F.3d 1248 (9th Cir. 2017):
Moreover, when confronted with signs of a burglary, investigating officers are entitled to protect their own safety. See Sandoval , 756 F.3d at 1163. We have previously observed that "when officers suspect a burglary in progress, they have no idea who might be inside and may reasonably assume that the suspects will, if confronted, flee or offer armed resistance." Frunz v. City of Tacoma , 468 F.3d 1141, 1145 (9th Cir. 2006). Thus, "[s]o long as the officers have established probable cause for a burglary, in such exigent circumstances, the police are entitled to enter immediately using all appropriate force. " Sandoval , 756 F.3d at 1163 (quoting Frunz , 468 F.3d at 1145 ; alterations incorporated). This factor weighs in favor of the City in this case.
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