In People v. Ramey (1976) 16 Cal. 3d 263, the People argued that Penal Code section 836 authorized a warrantless arrest whenever the police have probable cause to believe that the suspect has committed a felony, and that the only statutory limitation in effectuating a residential arrest is the knock-notice requirement of Penal Code section 844. (16 Cal. 3d at pp. 270-271.) The holding of Ramey is a constitutional limitation on this statutory authority to arrest. Relying on both the state and federal Constitutions, the California Supreme Court held that "the right of the people to be secure in their persons and houses against unreasonable seizures applies to arrests within the home, and that warrantless arrests within the home are per se unreasonable in the absence of exigent circumstances." (Id. at pp. 275-276.)