State v. Peacock
In State v. Peacock, 2005 WL 1227788 (Del.Com.Pl.), the Court reiterated that subjects may be removed from scenes without "probable cause" as part of an "investigatory detention" when the transportation is necessary and reasonable under the circumstances.
In that case the Court considered the police officer's testimony that it was raining and the road was dark. The traffic stop occurred on an incline. For these reasons, the officer elected to have the defendant perform field sobriety tests at the Troop and removed him from the scene.
The Court held that the transportation of the defendant was "reasonable and necessary" based upon those facts.