In Freeman v. Dept. Motor Vehicles (1969) 70 Cal.2d 235, Deputy Sheriff Fowler observed Freeman driving in an apparent state of intoxication and stopped his vehicle. He then summoned the assistance of Highway Patrol Officer Byrd, who made the arrest. When the defendant refused to submit to a chemical sobriety test, his license was suspended by the DMV. (Id. at pp. 235-236.) Freeman challenged the license suspension on the ground that his arrest was unlawful because Officer Byrd did not see him commit the misdemeanor of drunk driving. The state Supreme Court framed the question as follows: "If a peace officer 'stops' a motor vehicle driver for an alleged misdemeanor traffic offense committed in his presence, may a valid arrest be made by another peace officer who was summoned by the first peace officer but did not see the driver commit the alleged offense?" (Freeman, supra, 70 Cal.2d at pp. 236-237.) The court answered this question affirmatively, stating in part: "Officer Byrd was not the sole arresting officer. Deputy Sheriff Fowler, by 'stopping' plaintiff for the alleged offense and detaining him pending arrival of an officer of the highway patrol, initiated, and thereby participated in, the arrest. (See Pen. Code, 834, 835.) Deputy Sheriff Fowler did not himself complete the arrest, but it was completed by a person he had summoned to aid him in making the arrest, as he was entitled to do under section 839 of the Penal Code. That section reads: 'Any person making an arrest may orally summon as many persons as he deems necessary to aid him therein.'" (Freeman, supra, 70 Cal.2d at p. 237.) Inasmuch as Deputy Sheriff Fowler personally observed the conduct and related his observations to Highway Patrol Officer Byrd, who assisted Fowler by making the arrest, the court held that the requirements of Penal Code section 836 were satisfied. (Freeman, at pp. 237-238.)