People v. Meyer (1985)

Id. at 152, 156 .

The Supreme Court indeed indicated that police “officers acting outside their jurisdiction but not in fresh pursuit may not utilize the power of their office to gather evidence or ferret out criminal activity not otherwise observable” so as “to prevent officers from improperly asserting official authority to gather evidence not otherwise obtainable.” Id. at 159 (quotation marks and citation omitted).

The officer’s actions will be considered lawful if the circumstances attending would authorize a private person to make the arrest.”); State v. Washington, 444 So.2d 320, 324 (La.Ct.App.1983) (finding that officers made legal arrest outside their territorial jurisdiction as they were in close pursuit, but noting that under Louisiana statutory law “even if the officers were acting only as private citizens when they effectuated the arrest, it was valid”); Stevenson v. State, 2…

See People v. Meyer, 424 Mich. 143, 156 , 379 N.W.2d 59, 65 (1985). 9 . 507 Pa. at 407 , 490 A.2d at 426 ; see also United States v. Searp, 586 F.2d 1117, 1123 (6th Cir.1978), ce rt. denied, 440 U.S. 921 , 99 S.Ct. 1247 , 59 L.Ed.2d 474 (1979); Commonwealth v. Musi, 486 Pa. 102, 115 , 404 A.2d 378, 385 (1979) ("A rule of exclusion is properly employed where the objection goes to the question of the reliability of the challenged evidence or reflects intolerable government con…

See State v. Filipi, 297 N.W.2d 275 (Minn.1980)(extraterritorial arrest not unlawful where police had valid basis for arrest based on undercover drug operation); see also People v. Meyer, 424 Mich. 143 , 379 N.W.2d 59 (1985)(noting unique characteristics of undercover drug operations and refusing to dismiss felony complaint sworn by undercover officer who bought drugs outside of his jurisdiction at defendant’s invitation).

See People v. Meyer, 424 Mich. 143 , 379 N.W.2d 59 (1985).