Mendoza

This case presents difficult search and seizure issues involving the warrantless entry of a home and search of a shoulder bag found inside.

About 3:15 p.m. on June 22, 1983, Carl Vidano, a Huntington Beach narcotics sergeant, received a tip from a reliable informant that a Latin male named Jose, driving a white Volkswagen Jetta, would deliver at least a pound of cocaine to a certain home on Loclea Avenue within an hour. Vidano had known the informant for more than 4 years, and he had supplied reliable information on at least 10 previous occasions which led to the arrest of some 13 persons in narcotics related cases.

Vidano identified the occupant of the residence (not the defendant) via a utility company and set up a surveillance of the premises with two other narcotics officers within the hour. Three vehicles were parked in front. About 20 minutes later, Jose Mendoza arrived in a fourth, a white Volkswagen Jetta. Carrying a tan cloth shoulder bag, he entered the house.

Vidano met two uniformed patrol officers several blocks away. He had decided to "[s]ecure the residence and conduct a narcotics investigation." He believed there was insufficient time to…