Los Angeles County v. Rettele
Citation and Court
550 U.S. 609 (2007) — Supreme Court of the United States
Facts
Officers executed a valid search warrant at a home, not knowing that the suspects described in the warrant had moved. The current residents, a white couple, were ordered out of bed at gunpoint and detained for several minutes while officers cleared the home. The residents sued, claiming an unreasonable search and seizure.
Issue
Whether officers executing a valid search warrant act unreasonably by detaining occupants of the premises in a manner based on the description of suspects, even when those occupants are not the named suspects.
Holding
The detention was reasonable; officers executing a valid warrant may take reasonable steps to secure the premises, including briefly detaining occupants, even if those occupants are not the suspects named in the warrant.
Rule / Doctrine
Michigan v. Summers permits detention of occupants during execution of a search warrant. When officers act on a warrant and have legitimate safety concerns, briefly detaining and securing persons on the premises is reasonable even if they turn out not to be suspects. Officers are not required to anticipate every contingency; they may act on reasonable, if mistaken, assumptions.
Significance
Confirms that the authority to detain under Summers extends to all persons present, not just known suspects, provided the manner of detention is reasonable given the circumstances officers reasonably perceived at the time.