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$ whether probable cause is neeGed to justify search of suspect's premises in attempting to execute an arrest ° warrant. upon him. However, Since there is no allegation thet the assertion seems a considerable overstatement of existing case law. 8/ In addition, there was no evidence cited in the FEI memprandum that the premises entered could reasonabiy have been as spmed to be Hearst's residence. 2 , _ ° 1 Although the issue was not specifically raised; Pater, Joines, and Retcleza generally support the proposition that ‘probable cause is not necessary to search a suspect's premise in Order to execute an arrest warrant upon hin. 2/ powevery a 21274 Ninth Circuit opinion 10/ specifically held th probable cause is required to search the premises 6f the suspect in attempting to execute an arrest warrant. Finally, U.s. v. Dorman 11/ somewhat obliquely states that "concevts of probable cause and reasonableness. prima facie justify looking Foz @ man at home after 10:00 p.n.' Thus, the existing case law is divideG on tne chestior of eS - premises entered in Alexandria belonged to Eearst, the above discussion has no relevance to that incident. ‘B. Authority to use froze to enter prenises where ot _adnittance is denied - The walidity of an entry to execute an arrest, either with or without an, arrest warrart, is tested by criterié identical to those embodied in 16 U.S.C. §3105. 12/ That sec~ tion provides: 1 . The officer may break open any cuter or . inner @oor or window of a house, or any part of a house, or anything therein, to = execute a search warrant, if, after notice = of his authority and purpose, he is refuse admittance or when necessary to liberate himseii or a person aiding him in the execu- tion of the warrant. ; Accordingly, before force may be used to enter a premise to execute an arrest warrant, the officers must as a general rule announce both their authority anc purpose.: There is no require- ment that the officers provide Gocumentstion of their authority 4 + =