The following excerpt is from U.S. v. Garcia, 997 F.2d 1273 (9th Cir. 1993):
In some circumstances, officers can obtain an invitation to enter a private place through a ruse in order to investigate criminal activity. Lewis v. United States, 385 U.S. 206, 211, 87 S.Ct. 424, 427, 17 L.Ed.2d 312 (1966); United States v. Bosse, 898 F.2d 113, 115 (9th Cir.1990). There are limits to this, however.
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