What is the test for probable cause under the Fourth Amendment?

Probable cause for arrest exists only when the facts known to the arresting officer "would lead a man of ordinary care and prudence to entertain an honest and strong suspicion that the person arrested is guilty of a crime." (People v. Price (1991) 1 Cal.4th 324, 410.) When a detention exceeds the boundaries of a permissible investigative stop, the detention becomes a de facto arrest requiring probable cause. (People v. Gorrostieta (1993) 19 Cal.App.4th 71, 82-83.)

"A search conducted without a warrant is unreasonable per se under the Fourth Amendment unless it falls within one of the 'specifically established and well-delineated exceptions.' [Citations.] It is 'well settled that one of the specifically established exceptions to the requirements of both a warrant and probable cause is a search that is conducted pursuant to consent.'" (People v. Woods (1999) 21 Cal.4th 668, 674.) Evidence obtained as a result of a consent search is still subject to suppression, however, if the consent was given after a detention or arrest that violated the Fourth Amendment. (Florida v. Royer (1983) 460 U.S. 491, 501.)

Defendant contends his detention was converted to a de facto arrest that must be supported by probable cause because he was handcuffed. Defendant appears to concede that a reasonable suspicion for an investigatory detention existed. Although defendant acknowledges that police conducting investigations may take "reasonable precautions," such as handcuffing a suspect, if they are "reasonably necessary" (People v. Stier (2008) 168 Cal.App.4th 21, 27), he argues that the use of handcuffs during an investigatory detention is justified only if the officer has a "reasonable basis

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