In People v. Wetzel (1974) 11 Cal.3d 104, the defendant passively stood in her apartment doorway and refused to permit police officers to enter the apartment to search for a burglary suspect. She was arrested for obstructing an officer in the performance of his duties. Because the totality of her conduct constituted only a refusal to permit the officers to enter the apartment, the court concluded that her arrest was unlawful and reversed her conviction. (Ibid.)