Read the following excerpt from a US court opinion:
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principles, this Court has long recognized three categories of police interactions with private citizens: (1) a full-scale arrest, which requires probable cause, see Dunaway v. New York, 442 U.S. 200, 209-10, 99 S.Ct. 2248, 60 L.Ed.2d 824 (1979); State v. Echols, 382 S.W.3d 266, 277 (Tenn.2012); (2) a brief investigatory detention, requiring reasonable suspicion of wrongdoing, see Terry v. Ohio, 392 U.S. 1, 25-26, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968); State v. Williamson, 368 S.W.3d 468, 474 (Tenn. 2012); and (3) a brief police-citizen encounter, requiring no objective justification, see United States v. Mendenhall, 446 U.S. 544, 553, 100 S.Ct. 1870, 64 L.Ed.2d 497 (1980); State v. Ingram, 331 S.W.3d 746, 756 (Tenn.2011). See United States v. Berry, 670 F.2d 583, 591 (5th Cir.1982) ; Nicholson, 188 S.W.3d at 656; State v.
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What is the most suitable continuation to the opinion? Your options are:
A. recognizing that warrantless arrests with probable cause do not give rise to  1983 claims
B. holding in an impliedconsent case that a warrantless police entry was unlawful in part because the police did not request entry
C. holding that the police officers had probable cause to make a warrantless entry
D. holding that police officers warrantless search of rented home with consent of landlord but not tenant violated tenants fourth amendment rights
E. recognizing a threetier analysis for warrantless encounters with police
Reply with [A, B, C, D, E] only.