Arrest is defined as "a substantial physical intervention with the liberty of a person, resulting in his apprehension and detention." An arrest must be executed in accordance with the fourth amendment which prohibits unreasonable searches and seizures (the courts have interpreted "seizures" to include arrests). Under this amendment, "probable cause" is required for any "seizure" (arrest). Probable cause carries varied meanings depending on who is making the analysis; virtually all courts and commentators agree that it is more than "reasonable suspicion" but less than actual proof. The relevant court cases presented, most of which have been rendered by either the U.S. Supreme Court or Federal circuit courts, pertain to the probable cause requirement, arrest with warrant, arrest without warrant, the warrantless entry of a suspect's dwelling to effect an arrest, entries of third-party dwellings to effect arrest, the use of force to effect arrest, and substantive and procedural due process of law.