Atwater v. Lago Vista
In Atwater v. Lago Vista, 532 U.S. 318, 345, 121 S.Ct. 1536, 149 L.Ed.2d 549 (2001), the Supreme Court acknowledged that nuanced judgments about the need for warrantless arrest were desirable, but we nonetheless declined to limit to felonies and disturbances of the peace the Fourth Amendment rule allowing arrest based on probable cause to believe a law has been broken in the presence of the arresting officer. Id., at 346-347, 121 S.Ct. 1536.
The rule extends even to minor misdemeanors, we concluded, because of the need for a bright-line constitutional standard. If the constitutionality of arrest for minor offenses turned in part on inquiries as to risk of flight and danger of repetition, officers might be deterred from making legitimate arrests. Id., at 351, 121 S.Ct. 1536.
The Supreme Court found little to justify this cost, because there was no "epidemic of unnecessary minor-offense arrests," and hence "a dearth of horribles demanding redress." Id., at 353, 121 S.Ct. 1536.