Is there any case law where a police officer's on-the-scene assessment of probable cause provides legal justification for arrest?

It is well settled that although a policeman's on-the-scene assessment of probable cause provides legal justification for arrest and for a brief period of detention for administrative steps incident to arrest, the fourth amendment requires a judicial determination of probable cause before an individual may be subjected to an extended restraint of liberty. Gerstein v. Pugh, 420 U.S. 103, 113-14 (1975).

We recently affirmed a district court decision requiring that Santa Clara County either: (1) provide for a probable cause determination within twenty-four hours of a warrantless arrest (in view of evidence establishing that county law enforcement officials required no more than ten hours to complete administrative procedures), or (2) establish exigent circumstances precluding such a determination. Bernard v. City of Palo Alto, 699 F.2d 1023, 1024 (9th Cir.1983) (plaintiff arrested without warrant and held for fifty-one hours before release without probable cause determination brought suit against county, county officials and employees for damages, alleging violation of fourth amendment).