he called the dispatcher for assistance, the occupants had already been handcuffed. And the record provides no indication that the occupants threatened his safety. Moreover, if Reilly had not been concerned that the occupants would discard evidence, he and Horn could have driven the four, two to a car. Instead, he opted to wait for separate transportation, so the suspects could not leave contraband in the patrol car and possibly blame their fellow passengers. Reilly also had an objective reason to believe that Voichahoske was concealing evidence and that given the opportunity, he might destroy it. Reilly already had probable cause to believe Voichahoske was concealing drugs on his person, which, in turn, justified his arrest. See State v. Dussault, 193 Neb. 122, 225 N.W.2d 558 (1975) (<HOLDING>). Because a search of his person was
holding fourth amendment protects right to be free from arrest without probable cause holding invalid warrant did not create probable cause for arrest holding that probable cause is a complete defense to an action for false arrest holding that under fourth amendment standards for determining probable cause for arrest and probable cause for search and seizure are same holding that warrantless arrest based on probable cause did not violate the fourth amendment