door when Sauta and agents knocked and announced their presence, it was necessary for the agents to enter the room in order to secure her removal from the premises. Further, Defendant also later directed agents to inform Nishimura of his wish that she pack and keep his personal belongings. Police must be allowed to protect themselves before a potential threat of danger develops into a tragedy. Flippin, 924 F.2d at 166. In Flippin, the Ninth found the evidence at issue was not subject to suppression because the search and seizure were based on exigent circumstances related to the potential danger to the officer and others. Id. at 167. The court relied heavily on Buie, which recognized a lower standard than probable cause under such circumstances. See Buie, 494 U.S. 325, 110 S.Ct. 1093 (<HOLDING>) Moreover, the Ninth Circuit distinguished
holding that an arrest made by an officer outside his jurisdiction does not violate the fourth amendment holding that warrantless arrest based on probable cause did not violate the fourth amendment holding on similar facts that when an investigation on the scene develops probable cause to arrest the third party resident of those premises for harboring the fugitive a warrantless search incident to the arrest may then be made holding that officers were not justified in conducting a protective sweep of the suspects garage and backyard incident to his arrest for possession of marijuana in the back yard because the government pointed to no specific articulable facts suggesting that someone else was on the premises who posed a danger to the officers holding the fourth amendment permits a properly limited protective sweep in conjunction with an inhome arrest when the searching officer possesses a reasonable belief based on specific and articulable facts that the area to be swept harbors an individual posing a danger to those on the arrest scene