Timothy Jarrod Colburn v. Susan Odom

TJOFLAT, Circuit Judge:

*1111 The Fourth Amendment requires that a person who has been arrested and detained without a warrant must "promptly be brought before a neutral magistrate for a judicial determination of probable cause," generally within forty-eight hours. Cty. of Riverside v. McLaughlin , 500 U.S. 44 , 53, 111 S.Ct. 1661 , 1668, 114 L.Ed.2d 49 (1991). The States have discretion in how "to integrate [these] prompt probable cause determinations into their differing systems of pretrial procedures." Id.

In Alabama, a person who has been arrested and detained without a warrant must receive an…