by approaching the Buick and detaining him. See Doc. # 18 at 1. Since the Defendant did not make a similar argument in his post-hearing memorandum, it has been waived. However, if the Defendant had made such an argument, the Court would have rejected same. The Fourth Amendment limits the ability of government agents to conduct searches and seizures. Since the officers did not search or seize the Defendant by approaching the Buick in which he was passed out, they did not violate the Fourth Amendment by doing so. Based upon reasoning set forth below, the Court concludes that the detention of the Defendant was a lawful arrest supported by probable cause. Therefore, that detention did not violate the Fourth Amendment. See Beck v. Ohio, 379 U.S. 89, 85 S.Ct. 223, 13 L.Ed.2d 142 (1964) (<HOLDING>). 4 . The Defendant also contends that
holding that an arrest made by an officer outside his jurisdiction does not violate the fourth amendment holding that a warrantless arrest on probable cause does not violate the fourth amendment even if state law required the police to have prior authorization holding that a warrantless arrest does not violate the fourth amendment if at the time of the defendants arrest police had probable cause to believe that an offense has been is being or will be committed holding a warrantless arrest by a law officer is reasonable under the fourth amendment where there is probable cause to believe that a criminal offense has been or is being committed holding that warrantless arrest based on probable cause did not violate the fourth amendment