§ 5.9.1 Sweeps Incident to Lawful Arrest
An officer may conduct a protective sweep incident to arresting an individual inside his residence, Maryland v. Buie, supra, or outside his residence. State v. Kosman, 181 Ariz. 487, 892 P.2d 207 (App. 1995) (Div. 1) (“A bullet fired at an arresting officer standing outside a window is as deadly as one that is projected from one room to another.”). Incident to a lawful arrest, police may make a limited warrantless search of a residence as part of a “protective sweep.” State v. Fisher, 226 Ariz. 563, 565, 250 P.3d 1192, 1194 (2011). Such searches do not require probable cause. Id. See State v. Wilson, 237 Ariz. 296, 299, 350 P.3d 800, 803 (2015) (“[i]ncident to a lawful arrest, police may make a limited warrantless...
