What is the current state of the law on the most intrusive encounter between a police officer and a suspect?

"New York", United States of America

The following excerpt is from People v. Yonis, 2008 NY Slip Op 52417(U) (N.Y. Dist. Ct. 11/25/2008), 2008 NY Slip Op 52417 (N.Y. Dist. Ct. 2008):

4. Level Four, "a police officer may arrest and take into custody a person when he has probable cause to believe that person has committed a crime, or offense in his presence." People v. DeBour, supra at 223. Clearly, this is the most intrusive level of encounter.

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