Can a police officer's arrest be valid as a citizen's arrest?

As the court in People v. Richards, supra, held, in order to validate a police officer's arrest as a citizen's arrest, there must be some evidence to the effect that the citizen requested the police officer to perform the physical act of taking the suspect into custody. (72 Cal.App.3d at p. 510, 140 Cal.Rptr. 158.) The citizen's request need not, however, be express, but may be implied by the citizen's conduct in summoning police, reporting the offense and pointing out the offender. (See Green v. Department of Motor Vehicles (1977) 68 Cal.App.3d 536, 541, 137 Cal.Rptr. 368.)

Weatherford's actions in summoning police, following the suspect, pointing the suspect's whereabouts out to police, and thereafter effecting a citizen's arrest, reasonably support the inference that it was his intention that the prowler be arrested (cf. Green v. Department of Motor Vehicles, supra) and that had he known at the outset that it was necessary for him to effect the arrest, he would have delegated that authority to the police, as the law allows him to do (People v. Sjosten, supra).