Americans could not reasonably be expected to arrange presentment before a United States magistrate. Cf. United States v. Chadwick, 415 F.2d 167, 170 (10th Cir.1969) (“Courts have, however, generally recognized an exception to the applicability of Rule 5(a) to arrested persons in state custody for the simple reason that such persons cannot be conveniently arraigned while in state custody.”). The alternate means by which the Defendants could challenge the Government’s failure to present them to a magistrate before their arrival in the United States is the “working arrangement” rule, which provides that federal officials may not collude with state officers to circumvent federal presentment requirements. See Anderson v. United States, 318 U.S. 350, 356, 63 S.Ct. 599, 87 L.Ed. 829 (1943) (<HOLDING>). This doctrine has infrequently been applied
holding that officers were entitled to rely on the judicial officers finding of probable cause in issuing the search warrant unless they knowingly made false statements to obtain the warrant and that a challenge to the adequacy of the officers investigation does not rise to level of clearly established constitutional violation holding that statements may be excluded even in a case where federal officers themselves were not formally guilty of illegal conduct if the evidence is secured improperly through collaboration with state officers holding that officers were entitled to qualified immunity where defendant officers could have reasonably believed that they were given sufficient third party consent to search holding that the appellant could not complain that an affidavit and mediated settlement agreement were not in evidence even though those documents were not formally offered and admitted holding that compliance with an officers orders is a material fact when deciding whether the officers use of force was reasonable