How has the court interpreted the probable cause test for a search warrant application?

First, the court noted that there was a prearrest "seizure" of defendant and it assumed the seizure was without probable cause. (Michigan v. Summers, supra, 452 U.S. 692, 696.) After stating the importance of the probable cause standard, the court noted that "some seizures significantly less intrusive than an arrest have withstood scrutiny under the reasonableness standard embodied in the Fourth Amendment. In these cases the intrusion on the citizen's privacy 'was so much less severe' than that involved in a traditional arrest that 'the opposing interests in crime prevention and detection and in the police officer's safety' could support the seizure as reasonable. [Citation.]" (Id. at p. 697.) Conversely, the court noted several cases in which it held a detention was unreasonable in the absence of any articulable facts available to the officer. (Id. at p. 699, fn. 9.) The court concluded: "These cases recognize that some seizures admittedly covered by the Fourth Amendment constitute such limited intrusions on the personal security of those detained and are justified by such substantial law enforcement interests that they may be made on less than probable cause, so long as police have an articulable basis for suspecting criminal activity." (Id. at p. 699.) The applicability of this exception for limited intrusions that are justified by special law enforcement interests depends upon the character of the official intrusion and its justification. (Id. at p. 701.)