I don't know what your source is here, but I have a better one:The presence requirement:
In general, the misdemeanor arrest rule requires a crime to be committed in an officer’s presence before an officer can make a misdemeanor or gross misdemeanor arrest.5 Presence means that the officer perceived the offense through his or her senses, usually through direct observation.
There is an important timing aspect that is implicit in the presence requirement – if an officer was not there at the time the crime was committed, the presence requirement is not satisfied.11 Under
the completed misdemeanor rule, officers cannot make an arrest – or an investigatory stop – for acompleted misdemeanor or gross misdemeanor offense that is days old.12 However, courts have also carved out an exception for crimes that have been completed “in thevery recent past.”13 When an officer arrives on the scene within moments after the crime was
completed, courts still give officers the authority to stop the individuals who committed the crimand make an arrest.14
Minnesota courts have yet to precisely decide the duration of “the very recent past exception,” budo offer some guidelines. For example, in one case, the court held that “very recent past” rulwould allow an arrest for a misdemeanor one hour after the offense.
Scroll down to APPENDIX:
State Statutes Authorizing Warrantless Misdemeanor Arrests
My state, Ohio, permits an arrest for a misdemeanor theft not committed "in presence" as long as it is within a reasonable time after it's commission.
'Round these parts, some stores photocopy a shoplifting suspect's ID, take a photo, try to get a statement/admission, and ship all of that along with an incident report to the police department. The suspect is released after the store completes its investigation, but may well get a summons some time later.
(F) Any peace officer may arrest without a warrant any person that the officer has probable cause to believe has committed any act described in division (B)(1) or (2) of this section , that the officer has probable cause to believe has committed an unlawful taking in a mercantile establishment, or that the officer has reasonable cause to believe has committed an act prohibited by section 2913.07 of the Revised Code. An arrest under this division shall be made within a reasonable time after the commission of the act or unlawful taking.
There are other exeptions to the "in presence" requirement.
The federal constitution has NEVER mandated a crime, even a minor one, be committed 'in the presence" of an officer to conform to the 4th AM.
BOR & Aaron...
Would reasonable time start from the time of the theft or the time of the DISCOVERY of the theft?