Rhamell Burke, accused of murdering retired teacher Ross Falzone at a Chelsea train station, has been ordered held without bail without bail by a Manhattan judge after prosecutors detailed a pattern of violent assaults against police and innocent bystanders in the city's subway system. Over the last four months, Burke has been arrested four times for crimes including petit larceny and burglary, but was released without bail. On the day of the murder, police had taken Burke to Bellevue Hospital for a psychiatric evaluation, but he was released from within an hour. Falzone, 76, was pushed down the stairs with a massive brain injury. The incident occurred during a random attack.