CA3: Being taken to a police station interrogation room in handcuffs was a de facto arrest

Defendant was de facto arrested when he was taken in handcuffs from the place of his seizure to a police station and placed in a holding cell for interrogation. United States v. Wrensford, 2017 U.S. App. LEXIS 13894 (3d Cir. July 31, 2017).

“Based on a review of the record, the trial court could reasonably determine that Officer Rodriguez diligently pursued a means to confirm or dispel his suspicions and the detention was not so long as to become constitutionally prohibited,” and that defendant consented to a search of his wallet for an ID card that proved to be false. Alfaro-Jimenez v. State, 2017 Tex. App. LEXIS 7225 (Tex. App. – San Antonio Aug. 2, 2017).*

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