that Fowler’s presence when the misdemeanor was committed is relevant to Barry’s constitutional claim. The Fourth Amendment protects persons against “unreasonable searches and seizures.” U.S. Const, amend. IV. The “reasonableness” and hence constitutionality of a warrantless arrest is determined by the existence of probable cause. See, e.g., United States v. Hoyos, 892 F.2d 1387, 1392 (9th Cir.1989). The requirement that a misdemeanor must have occurred in the officer’s presence to justify a warrant-less arrest is not grounded in the Fourth Amendment. See Street v. Surdyka, 492 F.2d 368, 371-72 (4th Cir.1974) (cited in Welsh v. Wisconsin, 466 U.S. 740, 756, 104 S.Ct. 2091, 2101, 80 L.Ed.2d 732 (J. White dissenting) (1984)). See also Clark v. Link, 855 F.2d 156, 161-63 (4th Cir.1988) (<HOLDING>); Moore v. Marketplace Restaurant, Inc., 754
holding that a contracts clause violation may support a  1983 claim holding that violation of state law was not a per se constitutional violation holding that section 1983 actions based on violation of the fourth amendment may not rest on violation of state law holding that a violation of the wellestablished rule of brignoniponce constituted an egregious violation of the fourth amendment holding that  1983 does not provide a remedy if there is no violation of federal law