In Gerstein v. Pugh, the U.S. Supreme Court held that under the fourth amendment a locale must present an arrestee to a judicial officer for a probable-cause hearing upon completion of the "administrative steps incident to arrest." The Court failed to resolve a series of issues relating to postarrest presentment. The Court did not prescribe any particular time limit as an unconstitutional delay, and it did not specify what constitutes appropriate "administrative steps incident to arrest." Also, the Court did not state whether it is constitutional for a State to join the probable-cause hearing with an ordinary preliminary hearing if this would delay a probable-cause determination. The mechanism provided in "Gerstein" to protect an arrestee's fourth amendment rights is too nebulous a standard to guarantee that the rights are not compromised upon arrest. This article proposes that the U.S. Constitution requires the locality in which a person is arrested to provide a determination of probable cause within 24 hours of arrest or upon the completion of the administrative steps incident to arrest, whichever is sooner. 277 footnotes