home to obtain identification, and the officer has a “right to remain literally at [the arrestee’s] elbow at all times.” Id. at 6, 102 S.Ct. 812. Because the Supreme Court recognized that “[e]very arrest must be presumed to present a risk of danger to the arresting officer,” this exception was crafted to satisfy “[t]he officer’s need to ensure his own safety[,] as well as the integrity of the arrest,” id. at 7, 102 S.Ct. 812, when the arrestee is permitted to reenter his home. Under the facts as presented by Watson, construed in the light most favorable to him, the officers did not accompany him into his home, but rather, waited until he had effectively exited before attempting to gain entry. See, e.g., United States v. Santana, 427 U.S. 38, 42-43, 96 S.Ct. 2406, 49 L.Ed.2d 300 (1976) (<HOLDING>). Under Chris-man, the officers would have been
holding that a canine sniff is a search for purposes of the fourth amendment holding that the observation of evidence in plain view is not a search for purposes of the fourth amendment and does not require a warrant holding that the doorway of the home is a public place for purposes of the warrant requirement of the fourth amendment holding that the notice requirement found in rule 41d is not required by the fourth amendment holding that it is a violation of the fourth amendment for police to bring members of the media or other third parties into a home during the execution of a warrant when the presence of third parties in the home was not in aid of the execution of the warrant