Eighth Circuit
Brown v. City of Bloomington, CV 15-11(DSD/DTS), 2018 WL 3614125, at *8 (D. Minn. July 27, 2018) (“It is also well established that a brief detention becomes an arrest when it exceeds what is reasonable under the circumstances.”).
Eubanks v. Lawson, 122 F.3d 639, 641 (8th Cir. 1997) (“An investigative stop may become an arrest requiring probable cause if it lasts for an unreasonably long time.”).
Peterson v. City of Plymouth, 60 F.3d 469, 475 n.8 (8th Cir. 1995) (stating that “based on the facts adduced at trial, viewed in the light most favorable to the officers, we now hold as a matter of law that Peterson’s detention in the back of the patrol car was an arrest and that a prudent police officer in the same circumstances could not have reasonably believed otherwise”).