California, United States of America
The following excerpt is from People v. Johnson, 231 Cal.App.3d 1, 282 Cal.Rptr. 114 (Cal. App. 1991):
Probable cause supports the recovery of cocaine from defendant's mouth (People v. Cappellia, supra, 208 Cal.App.3d 1331, 1336, 256 Cal.Rptr. 695) and, of course, justifies the one-minute struggle as a full arrest, making it unnecessary to analyze it as a mere detention.
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