With no explanation, chose the best option from "A", "B", "C" or "D". and quotations omitted); see also People v. Lewis, 109 Cal.App.3d 599, 167 Cal.Rptr. 326, 330 (1980). This is very similar to the Fourth Amendment test applied by this court, which provides that “[p]robable cause exists when, under the totality of the circumstances known to the arresting officers, a prudent person would have concluded that there was a fair probability that[the suspect] had committed a crime.” United States v. Buckner, 179 F.3d 834, 837 (9th Cir.1999) (citations and quotations omitted). Peng advances the following five arguments on appeal attacking application of qualified immunity to Gage. First, Peng argues that a civil dispute over ownership of land title documents cannot form the basis for probable cause. See, e.g., Stevens v. Rose, 298 F.3d 880, 884 (9th Cir.2002) (<HOLDING>); Allen v. City of Portland, 73 F.3d 232, 237

A: holding that appellants had no standing to challenge search of car because they had no ownership or possessory rights of any kind in the car
B: holding that search of car was not incident to arrest where arrestee had exited and locked car before he was approached by officer and then arrested
C: holding that an arrest to retrieve car keys where ownership of the car was in dispute was not supported by probable cause
D: holding that the factfinder may conclude that recovery is not likely when the car is left on street with keys in the car
C.