What is the Harvey-Madden rule on probable cause to arrest?

3 The Harvey-Madden rule developed in the context of proof of probable cause to make a warrantless felony arrest when the probable cause was purportedly possessed by another member of the police department. It subsequently has been applied in various contexts where the "probable cause" for arrest is not based on the underlying facts generated by police investigation but, rather is based on a warrant resulting from a magistrate's review of those facts as reported in documents supporting the arrest warrant. (See People v. Alcorn, supra, 15 Cal.App.4th at pp. 656-658, 19 Cal.Rptr.2d 47, discussing cases.) Cases involving probable cause to arrest generated directly from facts known to another officer have very little applicability in the misdemeanor context since, generally, arrests for misdemeanors not committed in the arresting officer's presence can only occur pursuant to a warrant. (Pen.Code, 836, subd. (a).)