Legal review · Links checked : the source is available · Scope & methodology
This record is not a citator check. Confirm later history and treatment before relying on it.
authority type
case
jurisdiction
federal_nationwide
publication status
published_united_states_reports
precedential status
binding
decision or issuance date
1991-05-13
subsequent history
Current official source reviewed through 2026-08-25.
negative treatment status
No contrary current enactment or Supreme Court holding identified in official-primary-source review through 2026-08-25; comprehensive commercial citator not run.
material limitations
Use only for the propositions and boundaries stated in the linked canonical module.
For the Fourth Amendment prompt judicial probable-cause determination required after a warrantless arrest, a determination within 48 hours generally complies, though an individual may show unreasonable delay; after 48 hours the government must demonstrate a bona fide emergency or other extraordinary circumstance.
Material limitation
The holding does not convert Rule 5's “without unnecessary delay” language or the McNabb–Mallory confession rule into a 48-hour threshold.