The following excerpt is from People v. Hazelwood, 104 Misc.2d 1121, 429 N.Y.S.2d 1012 (N.Y. City Ct. 1980):
We must first make a determination as to whether probable cause to detain the defendants existed in this case. Dunaway v. New York, 442 U.S. 200, 99 S.Ct. 2248, 60 L.Ed.2d 824. Clearly, the uncontradicted and credible evidence presented permitted the officer to detain the defendants for further action based upon the events that took place in the subway car.
The effect of the detention for the purpose of issuing a universal summons was to create an arrest situation. United States v. Ricard, 563 F.2d 45 (2d Civ., 1977). 1
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