Can an officer make an arrest without a directive or request from another officer or agency?

California, United States of America


The following excerpt is from People v. Ford, 150 Cal.App.3d 687, 198 Cal.Rptr. 80 (Cal. App. 1984):

It is well established that where an officer makes an arrest without a directive or request from another officer or agency, he may not justify the arrest on the existence of probable cause in the hands of the other officer or agency. Thus, in Salter v. State (1975) 163 Ind.App. 35, 321 N.E.2d 760 one officer had probable cause to arrest, another actually arrested and a search incident to the arrest netted heroin. There had been no communication between the officers. The court held the arrest illegal because of the absence of evidence of such a communication. This case is cited with approval in 1 LaFave, supra, section 3.5(c), pages 631-632.

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