It's hard to say. I have a hard time disagreeing with Professor Rigakos about the one-day limit. I obviously would grow more cautious as the time became expanded.
I would note that in David Chen's case, he was acquitted on the basis of the original legislation, so the one- to two-hour period really was of no consequence in terms of a reasonable time afterwards. The court concluded that it was a continuing offence, and therefore Mr. Chen fit within the existing contours of citizen's arrest: that this thief was coming back to commit another theft, and so it was one continuous act of theft.