Stemming from Atwater v.City of Lago Vista, the U.S.Supreme Court opted not to mandate the rules regarding arrests and misdemeanors but rather left it to the states to decide.

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In Atwater v. City of Lago Vista, the U.S. Supreme Court ruled that a warrantless arrest for a crime committed in an officer's presence does not violate the Fourth Amendment, even if the crime is a misdemeanor punishable only by a fine. This decision essentially left it to the states to establish their own rules and limitations regarding arrests for misdemeanors.

Stemming from Atwater V