California, United States of America
The following excerpt is from People v. Smith, C071695 (Cal. App. 2014):
analogous. (People v. Celis (2004) 33 Cal.4th 667, 680 ["Unquestionably, the work of a police officer in the field is often fraught with danger. At any given moment, a seemingly safe encounter or confrontation with a citizen can suddenly turn into an armed and deadly attack on the officer"].)
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