City of Oregon v. Szakovits

In State v. Lewis (1893), 50 Ohio St. 179, it was held thats

“Where 0 * 0 the officer was absent when * # ° [the] offense was committed, and did not appear there until after the affray had ended, public order restored, and the guilty parties had departed from the vicinity, and all the information the officer had of the affray and of the parties to it, was the statements of by-standers who witnessed it, he has no authority in law to pursue and arrest the persons charged with the offense without first obtaining a warrant therefor.”

The holding in Lewis was predicated upon the conclusion that the…