The following excerpt is from Ragbir v. Homan, 923 F.3d 53 (2nd Cir. 2019):
17 It is unclear that Fourth Amendment doctrine should be so readily applied to the circumstances here, as it has developed within the context of the particular interests served by criminal investigations. See, e.g. , Virginia v. Moore , 553 U.S. 164, 173, 128 S.Ct. 1598, 170 L.Ed.2d 559 (2008) ("[A]n arrest based on probable cause serves interests that have long been seen as sufficient to justify the seizure. Arrest ensures that a suspect appears to answer charges and does not continue a crime, and it safeguards evidence and enables officers to conduct an in-custody investigation." (internal citations omitted)).
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