I should say that as far as I'm concerned, the Chen case is maybe a more extreme circumstance than one would expect to deal with in the context of a typical, true citizen's arrest, in that we were dealing with a situation where the arrestee was hog-tied and put in a van. We're dealing with a fairly robust exercise of this power.
I think this goes to Professor Rigakos' point that courts have in fact bent over backwards to acquit individuals in these circumstances. It's probably an indication that the existing provisions provide sufficient protection to individuals in these cases.