The following excerpt is from United States v. Manning, 448 F.2d 992 (2nd Cir. 1971):
To me, this distinction is significant because in the case of a search warrant, the law enforcement officer has to appear before the magistrate who can question him further and call for more information or clarification if he is not satisfied that the officer's affidavit constitutes sufficient probable cause for issuing the warrant. Indeed, it is the intervention of an impartial judicial officer in deciding when probable cause exists that makes the search warrant an important safeguard against unwarranted intrusions by government agents into private dwellings. See United States v. Robinson, 325 F.2d 391, 394 (2d Cir. 1963). That safeguard, of course, is not present when the law enforcement officers themselves make the determination that they have probable cause for an entry in order to arrest. Hence, in my view, the test of probable cause required for entry without a warrant should be more stringently applied than that for obtaining a search warrant. Otherwise, private dwellings would be subject to warrantless invasions upon the law enforcement officers' suspicion, with the scantiest sort of corroboration, that a crime was being committed inside, and the policy underlying the search warrant requirement could be subverted. As I pointed out in the panel opinion, the circumstances leading to the entry in this case, in my opinion, fell far short of those which would justify a warrantless intrusion.
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