People v. Satterfield

I dissent. I do not agree that Deputy Hill, at the moment he kicked the door open, had reasonable cause to make an arrest inside the house, because I do not agree that he had reasonable cause to believe, at that moment, that there were narcotics in appellant’s possession on the premises.

Until the moment he kicked the door open, Deputy Hill had no knowledge of any specific prior crime in which appellant was implicated. Therefore, this was not a case where entry was justified because the officer had reasonable cause to believe (Pen. Code, § 836, subd. 3) that a person within the premises was…