What is the test for probable cause for a search of a person with a history of heroin possession?

When, in addition to other information possessed by the officer, the tell-tale injection marks were discovered, indicating recent injections of heroin into defendant's arm, sufficient basis for a search existed to the knowledge of the officer. He now has a well grounded suspicion of recent possession of heroin by defendant, a felony (Health and Safety Code, section 11500) and the conditions of section 836, subdivision 3 have been met fully. (See People v. Elliott, 186 Cal.App.2d 178, 182, 8 Cal.Rptr. 795; People v. Rios, 46 Cal.2d 297, 298-299, 294 P.2d 39.)

In People v. Elliott, supra, 186 Cal.App.2d at page 182, 8 Cal.Rptr. at page 798, it is said: 'Upon entering the room, the officer observed 'fresh hypodermic needle marks' on the appellant's left arm. The appellant, upon inquiry, said that he was not using narcotics, although he formerly did, and that his 'last fix was about two weeks ago.' In the light of such facts, there was probable cause for the arrest which then ensued.'

In People v. Rios, 46 Cal.2d 297, at pages 298-299, 294 P.2d at page 41, Mr. Justice Traynor stated: 'From defendant's admission that he had taken an injection of heroin two weeks before it could be inferred that he had possessed heroin in violation of Health and Safety Code section 11500. Moreover, since the validity of an arrest does not depend on whether the defendant may in fact be found guilty of the offense for which he is arrested [citations], and since in determining its validity the court is not limited to a consideration of evidence that would be admissible at the trial on the issue of guilt [citations], it is immaterial that defendant could not be convicted of possessing heroin without independent proof of the corpus delicti.' [Citations.]'

In People v. Symons, 201 Cal.App.2d 825, 830, 20 Cal.Rptr. 400, 404: 'As stated in People v. Williams, 196 Cal.App.2d 726, 728, 16 Cal.Rptr. 836, 837: 'The rule should not be understood as placing the ordinary man of ordinary care and prudence and the officer experienced in the detection of narcotics offenders in the same class. Circumstances and conduct which would not excite the suspicion of the man on the street might be highly significant to an officer who had had extensive training and experience in the devious and cunning devices used by narcotics offenders to conceal their crimes.''