With no explanation, chose the best option from "A", "B", "C" or "D". op. at 4, 2005 WL 3447678 (Tenn.Crim.App., Jackson, Dec. 14, 2005). Because an arrest warrant may or may not issue upon the affidavit of complaint, the “affidavit of complaint will not necessarily provide a defendant with notice that he is being charged with an offense, and an affidavit of complaint, with nothing more to provide a defendant with notice, is not a charging instrument.” See id. Similarly, a citation issued by an officer in lieu of a custodial arrest is not a “formal accusation.” Just as a warrantless custodial arrest does not, alone, commence a prosecution, a citation issued in lieu of an arrest is not the result of an independent probable cause determination and, therefore, does not mark the beginning of the prosecution. See State v. Best, 614 S.W.2d 791, 795 (Tenn.1981) (<HOLDING>); see also Ferrante, 269 S.W.3d at 912 (noting

A: holding  1983 action lies for warrantless arrest without probable cause
B: recognizing the defense of good faith and probable cause in  1983 case involving unconstitutional warrantless arrest
C: holding that the plaintiff must show that there was a lack of probable cause for the criminal prosecution
D: holding in the case of a warrantless arrest that without a followup determination of probable cause either through the issuance of a warrant or a binding over to the grand jury the criminal prosecution terminates
D.