Does the Fourth Amendment prohibit an investigatory detention to investigate a completed misdemeanor?

There is a split of authority in the federal and state courts as to whether the Fourth Amendment prohibits an investigatory detention to investigate a completed misdemeanor. (See e.g., United States v. Hughes (8th Cir. 2008) 517 F.3d 1013, 1015, [daytime investigatory detention and frisk of black man, who was standing near a public bus stop and across the street from an apartment complex (located in high crime area) to which police had been dispatched based on an anonymous complaint of "suspicious parties on the property" and who matched the description given by dispatch], 1017 [declining "to adopt a per se rule that police may never stop an individual to investigate a completed misdemeanor" and stating "the nature of the misdemeanor and potential threats to

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