The following excerpt is from Tachiquin v. Stowell, 789 F. Supp. 1512 (E.D. Cal. 1992):
Michigan v. DeFillippo, 443 U.S. 31, 37, 99 S.Ct. 2627, 2632, 61 L.Ed.2d 343 (1979). Frequently, an officer may have probable cause for an arrest, while recognizing that based upon what the government knows at that time, proving the case at trial will be difficult. Arrest may be only the first stage in a criminal investigation and prosecution; as the investigation proceeds, additional evidence is frequently developed.
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