What is the test for a search warrant for in-home arrest?

Officers making an in-home arrest may without a warrant or probable cause make a cursory search of areas where people might be hiding. (Maryland v. Buie (1990) 494 U.S. 325, 334-335.) The search must be supported by "articulable facts which, taken together with the rational inferences from those facts, would warrant a reasonably prudent officer in believing that the area to be swept harbors an individual posing a danger to those on the arrest scene. (Id. at p. 334.)

Here deputies had reason to believe that one resident of the house was suspected of domestic violence and another resident had been convicted of selling narcotics. Firearms are one of the "'tools of the trade'" of narcotics sales. (People v. Ledesma (2003) 106 Cal.App.4th 857, 865.) The type of criminal conduct underlying the arrest or search is significant in determining whether a search is justified. (Ibid.) When deputies

Page 7