No reasonable man would contend that there can be no valid invasion of privacy by police officers. But, just when do the rights of society accede to the privileges of the individual? Certain guides as to the reasonableness of a search have been determined. A search, without a search warrant, is lawful if it is incident to a lawful arrest and if the essential element of a lawful arrest, probable cause, exists.
Mildred Schad, Police Liability for Invasion of Privacy, 16 Clev.-Marshall L. Rev. 428 (1967)
Police Tort Liability (Symposium)