State v. Kang
In State v. Kang, 2001 WL 1729126 (Del. Super.), the Court distinguished between an "investigatory detention," which must be supported by an officer's reasonable belief that a suspect has committed a crime and a "custodial arrest," which must be supported by an officer's possession of "probable cause" to believe that a suspect has committed a crime.
A court must determine whether a seizure is an "investigatory detention" or a "custodial arrest" based upon the totality of the circumstances. Investigatory detentions must be minimally invasive and limited in scope to be justified.
Police officers may transport suspects from a scene as part of an "investigatory detention" when such action is reasonable and necessary under the circumstances.