County of Riverside v. McLaughlin

County of Riverside v. McLaughlin, 500 U.S. 44 (1991) was a class action civil suit filed against Riverside County, challenging its practice of holding combined probable cause hearings and arraignments for persons arrested without a warrant. Under the County's procedures, arraignments were to be held within 2 days of arrest; this 2-day requirement, however, excluded weekends and holidays. The plaintiff sought declaratory and injunctive relief requiring the County to provide quicker probable cause determinations. In McLaughlin, the issue was whether the County's procedures comported with the Fourth Amendment's requirement for a "prompt" judicial determination of probable cause following a warrantless arrest as mandated by Gerstein v. Pugh, 420 U.S. 103 (1975). 500 U.S. at 47. In balancing the interests of the parties, the Court recognized that some delays were inevitable. 500 U.S. at 55. To provide more certainty in defining "prompt," however, the Court created a bright line rule that probable cause determinations had to occur within 48 hours of arrest in order to comply with Gerstein. Once the detention exceeded 48 hours, the government was required to show a bona fide emergency or justification for continuing the detention; the mere fact that a weekend intervened was not sufficient. 500 U.S. at 56-57.