The following excerpt is from U.S. v. Shephard, 21 F.3d 933 (9th Cir. 1994):
9 The government contends that State v. Plouffe, 198 Mont. 379, 646 P.2d 533 (1982), also establishes that a probation officer may orally authorize a probationer's arrest. In Plouffe, however, the appellant was arrested after a written as well as an oral authorization was made. Id. at 534. The issue whether an oral authorization alone would have been sufficient was not raised.
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