Sin

MEMORANDUM **

Our teachings in Arpin v. Santa Clara Valley Trans. Agency, 261 F.3d 912 (9th Cir.2001), require police officers to conduct additional investigation on a citizen’s arrest if there is some question in their minds as to the merits of the arrest. In Arpin, the court criticized the conduct of the officers because the officers failed to identify themselves, to inform the individual of the reasons for arrest and to allow the individual to explain her side of the story. In the present case, the officers reviewed a signed statement, interviewed both parties involved and made an objective decision regarding probable cause to arrest. This objectivity is the key, and the jury was charged with reviewing the totality of the circumstances to determine if the objectivity was reasonable. We determine that there was no error.

II.

A district court’s rulings on objections to alleged prosecutorial misconduct during closing argument are reviewed for an abuse of discretion. United States v. Sarkisian, 197 F.3d 966, 988 (9th Cir. 1999). Counsel are entitled to a reasonable degree of latitude in the presentation of closing argument. United States v. Molina, 934 F.2d 1440, 1445 (9th…