In Riverside County. v. McLaughlin, 500 U.S. 44, 111 S. Ct. 1661, 114 L. Ed. 2d 49 (1991), the United States Supreme Court held that any delay of more than forty-eight hours must be presumed unreasonable. Riverside Co., 500 U.S. at 56-57. The burden then falls on the government to demonstrate that extraordinary circumstances necessitated the delay. Riverside Co., 500 U.S. at 57. A shorter delay may also be unreasonable if it was unnecessary. Riverside Co., 500 U.S. at 56. It is significant that Riverside Co was a civil case dealing solely with the Fourth Amendment prohibition against unreasonable seizures. Riverside Co., 500 U.S. at 47. Riverside Co involved a federal class action by Donald McLaughlin seeking injunctive and declaratory relief on behalf of himself and "'all others similarly situated.'" Riverside Co., 500 U.S. at 47-48. McLaughlin's "situation" was quite simple. He was incarcerated in the Riverside County Jail and had not received a probable cause determination. Riverside Co., 500 U.S. at 48. A second amended complaint named three additional plaintiffs, individually and as class representatives, and asserted that each of these plaintiffs had been arrested without a warrant, had received neither a prompt probable cause hearing nor a bail hearing, and was still in custody. Riverside Co., 500 U.S. at 49. The federal district court issued an injunction. The Ninth Circuit Court of Appeals determined that Riverside County's policy of providing probable cause determinations within forty-eight hours of arrest was not in accord with Gerstein, which required a probable determination "promptly after arrest." Riverside Co., 500 U.S. at 50.