explain that part even well now the must must get it back to ground zero so you see what we can agree upon or not order when you agree that at this time the law was clear that ordinarily the in house arrest requires a warrant the arrest of an individual suspected of a crime in their own home requires a warrant if you would just walk into the house for the purpose there's no evidence of weapons present correct me no drugs agree this is someone and they had two too many dogs correct right and she had sort of the officer attempts to write her a citation she goes into her home correct i'm a little more than that the officer tried to write the citation she refused to give information the officer went to the truck the plate to follow the officer to the truck so not everything happening inside the house of the point then goes back inside then the officer shows up does i guess my question is does the refusal to give information sufficient to complete the citation would that  your point had shown up and absorb the information from the pet control officer he very probably would have had probable cause to arrest or at that time would you agree that if the question is what happens in the house ok and  the point and and that is we can't resolve facts the supreme court's told us that in the in this context our jurisdiction is limited to questions of law and if there is a dispute of facts as to whether this is  known by susan hoke the animal control officer susan hope was hired by her brother in law in the animal control officers her brother in law paul turner was the head of that office they knew her name so t sign a completed citation there was never a completed citation we put in the record the citation that existed in the form of existed before her arrest that is before she was taken down in her living  put in a police car talking about whether the matter of the wrist is one thing and whether they had probable cause to arrest the claim and there she had stayed there with the animal control officer but refused to give more information citation and the only citation that ever existed in a completed form that was presented to her signature she was already in the police vehicle under arrest there was no citation that had been presented to her for signature and i act because the animal control officer didn't complete it and didn't give it to her and susan hoke stated under oath in her testimony that she didn't believe she had any grounds for arrest at the time that surely good one retreated and went into her residence which she said she didn't have grounds to arrest the facts on the on the entry are far more severe than have been presented and argued the door was closed and this is good one was on the phone to paul turner her brother in law asking what her rights were she herself is a is a retired sergeant sheriff in san bernardino county and she asked what can happen and and he told her they're going to send you a long form citation and you should accept it and you should pay it and she was perfectly happy to do that and she was on the phone talking to him he's listening to the event as it happens when the officer opens the door himself which had been closed in fact her roommate mr to lower believes he had a lot to the door mistakenly any blames himself to this day he didn't so the officer had opened the door and had entered in the sense that he put his foot in put it shoulder against the door was in her entry way before she opened and gave permission or anything else that is no different than  a police officer without a warrant on a pet violation minor infraction only of that entering a residence without at that time any probable cause as admitted by susan how he developed probable cause after he control officer similarly herself did not have that knowledge she was trying to develop that knowledge of what this was her testimony citation she was what she knew at the time she was writing a citation trying to find out whether there was sufficient information i don't believe that my belief is that there weren't sufficient facts even for the him or her miss hope to know that there had been tapped i should there were violations might my client is a pet activist too who saves dogs and was known by the animal control they'd been out the month before on the exact same thing and have not arrested her under the exact same circumstances this was a draconian excess of the use of the already in her home so it's like it's belief based on having tried the case twice is that there was no probable cause to arrest i think the officer made up the screen door you are as a matter of fact there was not or as a matter of law there were as a matter of fact he didn't have any information that any crime had occurred and it's patently unbelievable that she could have tapped his left shoulder with the screen door and that's what that's when you're arrested are not talking about was good when it was in violation of the ordinance misdemeanor understand that the animal control officer was investigating those circumstances the office did no information about it and in fact she did have too many pets and two that weren't licensed however susan hope the animal control officer said she had no grounds for arrest that day and nothing was happening that day and she observed nothing that was a crime or a penalty offense of any co probable cause to write a citation for violation of an organ the the evidence is in conflict on that she didn't believe that she had enough information to even issue the citation at that point she didn't issue it until after the arrest  called the officer who came in and left you know that correctly determining that there was nothing that he that officer should do why a month later they decided to invade her home and arrest her i think  right now we're on  beginning ok there's the lottery be one as you say that because everybody was trying to figure out how to pronounce