We use both our own and third-party cookies for statistical purposes and to improve our services. If you continue to browse, we consider that you accept the use of these.
  • Celebrating 20 Years of Training Excellence 2004-2024

Entry to Arrest

The California Supreme Court in People v. Ramey (1976) 16 Cal.3d 263 and the U.S. Supreme Court in Payton v. New York (1980) 445 U.S. 573, both held that entry into a residence to arrest a suspect requires a warrant. Payton also requires that officers have probable cause to believe that (1) the suspect lives at the residence and (2) the suspect is currently present within the residence.

How about the suspect that is in a third person’s residence? The USSC in Steagald v. U.S. (1981) 451 U.S. 204, held that a warrant was necessary for officers to enter and arrest a suspect who might be in a friend or relative’s home. The USSC expanded the necessity of a warrant to a third party residence.

Each of the court rulings touched on the danger and invasive nature of a forced entry to a residence to effectuate an arrest.

It is critically important that the up to date officer understand the legal requirements necessary to enter a residence or private location to arrest a suspect.


Err on the side of caution. ANY location that is being used as a residence, home, apartment, motel, hotel, mobile home, tent and so may be ruled a residence for RAMEY/PAYTON/STEAGALD purposes. A private office in a building has also been ruled a location entitled to protection as well. It is ALWAYS better to obtain a search warrant prior to entry into a private location.


Remember, the only requirement for a warrant is to ENTER a residence. If the suspect is outside, on the threshold, hallway, at the open door, or on the front porch, a warrant is not required. Officers can get the suspect out of the house with a lie, a ruse, and you may also order the suspect to come out of the residence and then arrest her when she exits the residence. If the suspect opens the door, you may arrest her because she has made herself accessible to the public. By coming to the door, the suspect has made herself subject to public access and thus is in public. If the suspect at the door decides to run back into the residence, you can chase her back in and arrest her inside the residence.


In the 9th Circuit, officers have the right to reach inside the doorway to arrest a suspect when the suspect voluntarily opens the door, the door is open wide enough for the officers to see the suspect, and the officers identify themselves as officers.


You must have the legal right to enter, you must have probable cause to believe the suspect resides at that location and is inside the residence.


  • I highly recommend this training for any Probation staff who have the necessity to interview/interrogate individuals for investigation purposes.

    —R. Bret Fidler, Santa Clara County Probation Department
  • This training provided the useful tools necessary for assessing the veracity of a suspected child abuser, which goes a long way in helping to protect children.

    —Sunny Burgan, MSSW, LCSW, Social Work Supervisor, Santa Clara County DFCS
  • I will continue to use and pass on this information because I really believe in the instructors and their approach.

    —Kimberly Meyer, Washoe County Sheriff's Department
  • It not often that you go to a training that you really, really want to pay attention to. Because of the high quality information and style of presentation, I knew that if I looked away I was going to miss out.

    —Quinten Graves, Oregon State Police
  • This was, by far and away the best training I have received in 15 plus years of Law Enforcement. The instructors are experienced, engaging, articulate, and very entertaining. I will be recommending this training to multiple agencies.

    —Mark Paynter, Oregon DOC
  • This was, by far, one of the most useful training classes I've attended since becoming an investigator.

    —Steven Aiello, Antioch Police Department
  • Incredible training with amazing real world instruction. I have been taking law enforcement classes for over 30 years and by far this is the best presented and most useful.

    —Det. Brian Dale, Portland Police Bureau
  • This training by far has been the most informative and most effective I've attended. The instructors engaged the students in a manner that made me want to speak my opinion, ask questions, and participate.

    —Julio Ibarra, Merced County Sheriff’s Office
  • The information presented was highly relevant to my job and was presented in a manner that was organized and very easy to digest.

    —Michael McGarvey, California State Prison, San Quentin
  • Your training gave me the confidence and tools to interview the suspect for over 5 hours and to bring a closure to the case.

    —Daniel Phelan, San Jose Police Department
  • Instructional style is engaging and highly effective.

    —George Laing, Fire Prevention Captain, Investigator
  • Effective teaching teams! The presentation of the material was consistently interesting, and intelligent without being too intellectualized.

    —Michele Keller, Deputy Probation Officer, County of Alameda
  • Your training has made the greatest and most direct impact on my assignment of any training class that I've taken.

    —Ken Gelskey, National City Police Department