The following excerpt is from U.S. v. Ortiz- Villa, 111 F.3d 139 (9th Cir. 1997):
It is reasonable under the Fourth Amendment, and it is not an impermissible invasion of the privacy or personal liberty of an individual who has been arrested, for an officer to take steps to ensure the officer's safety. Maryland v. Buie, 494 U.S. 325, 333 (1990) (recognizing the "interest of the officers in taking steps to assure themselves that the house in which a suspect is being, or has just been, arrested is not harboring other persons who are dangerous and who could unexpectedly launch an attack"); accord Washington v. Chrisman, 455 U.S. 1, 7 (1982) (holding that an officer may accompany an arrested person into the arrested person's residence for the purpose of ensuring officer safety).
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