Task: Text Completion
Input (English): part by an officer’s interest in ensuring his own' protection and preventing a suspect’s flight during a Terry stop, most circuits today have approved police use of drawn weapons or handcuffs to restrain criminal suspects. Courts have' also permitted police to demand a suspect to lay prostrate on the ground during a stop and frisk search. In addition, .courts have allowed police to forcibly transport suspects (most notably to a patrol car) under a válid Terry stop. As a result, lower courts, while maintaining that Terry remains a limited exception, have authorized conduct similar to that associated with custodial arrest without converting that stop into a full-fledged arrest. Id. at 2805 (citations omitted); see also State v. Sheppard, 271 S,W.3d 281, 289 n. 28 (Tex.Crim.App.2008) (<HOLDING>). 33 . See Lefkowitz v. Turley, 414 U.S. 70, 
 Holding statements: (A) holding in the alternative that even if handcuffing a suspect did convert the detention into an arrest the arrest was justified by probable cause (B) holding that the limits of fourth amendment protection relate to the boundary between arrest and pretrial detention (C) holding that a search incident to a lawful arrest does not violate the fourth amendment (D) holding that in  1983 claims for malicious prosecution the fourth amendment applies to those actions which occur between arrest and pretrial detention (E) holding a fourth amendment terry detention is not a custodial arrest and the use of handcuffs does not automatically convert a temporary detention into a fourth amendment arrest
Output (English): (E)