People v. Dixon

Herman Lester Dixon appeals his conviction of unlawful possession of a narcotic drug.1

Dixon was arrested for a traffic offense and searched at the scene; nothing was found. Heroin was discovered during a search at the police station. Contending that both his arrest and the search were illegal, Dixon moved before and at trial to suppress the heroin.

The Court of Appeals, in holding that Dixon was validly arrested, "adopt[ed] the following rules”:

"A police officer may arrest without a warrant for a misdemeanor if the misdemeanor was actually committed in the officer’s presence or if, from…