The officer saw defendant recklessly driving, but wasn’t able to stop him. Staleness for arrest for that did not dissipate within three hours before he saw defendant again. Hairston v. Commonwealth, 2017 Va. App. LEXIS 99 (April 11, 2017) (see Treatise § 6.02 n.22).
The plaintiff is the elderly widow of a NASA engineer, and she needed to sell property to get by. She had a paperweight with a piece of lunar material in it for sale and called NASA about it. NASA set up to attempt to arrest her. She alleged that she was detained in a public parking lot for two hours, while she stood in urine-soaked pants, as the agent questioned her incident to a search about her possession of the paperweight. Qualified immunity denied. Davis v. United States, 2017 U.S. App. LEXIS 6348 (9th Cir. April 13, 2017).*