"We also believe that if a police officer makes a lawful arrest, it has the likelihood of being downgraded or completely voided."

Another common law rule—that permitting Searches incident to a lawful arrest without warrant—has been applied in American law.

The rule relating to searches incident to a lawful arrest established in this case is known as the Chimel rule.

To make a lawful arrest, an officer has to have reasonable cause to believe a crime has been committed.

The murder was committed for the purpose of avoiding or preventing a lawful arrest or prosecution.

The rule permitting searches incident to a lawful arrest has a lengthy common law history.

But there must be something more in the way of necessity than merely a lawful arrest.

The murder was committed to avoid or prevent a lawful arrest or to effect an escape from custody.

R. 279, to resist lawful arrest, the defendant held a girl in front of him as a shield and shot at armed policemen.

The same threat expressed by police officer making a lawful arrest would typically be considered lawful compulsion.