context: Although no per se duration exists at which a Terry stop ends and an arrest commences, a 20-minute confinement has been held too lengthy to be appropriately characterized as an investigatory deten tion.
citation_a.signal: see also
citation_a.identifier: 609 F.2d 1284, 1287
citation_a.parenthetical: holding that detention for three hours in a checkpoint station required .probable cause
citation_a.sentence: Sharpe, 470 U.S. at 686, 105 S.Ct. 1568 (overturning a Court of Appeals decision and ruling that a 20-minute detention was reasonable under Terry because the police acted diligently and a suspect’s actions contribute to the added delay); see also United States v. Perez-Esparza, 609 F.2d 1284, 1287 (9th Cir.1979) (holding that detention for three hours in a checkpoint station required .probable cause).
citation_b.signal: no signal
citation_b.parenthetical: overturning a Court of Appeals decision and ruling that a 20-minute detention was reasonable under Terry because the police acted diligently and a suspect's actions contribute to the added delay
citation_b.sentence: Sharpe, 470 U.S. at 686, 105 S.Ct. 1568 (overturning a Court of Appeals decision and ruling that a 20-minute detention was reasonable under Terry because the police acted diligently and a suspect’s actions contribute to the added delay); see also United States v. Perez-Esparza, 609 F.2d 1284, 1287 (9th Cir.1979) (holding that detention for three hours in a checkpoint station required .probable cause).