When making an arrest without a warrant, the general test which is used to determine whether a police officer can be held liable for civil damages under the false arrest theory is: a. did the defendant plead guilty to the suspected crime? b. did the defendant have a record of past crimes similar to the suspected crime? c. did the officer use the judgment of a reasonable person before he or she made the arrest? d. is "respondeat superior" an acknowledged principle in the jurisdiction where the arrest took place?