Michigan v. Summers
Citation and Court
452 U.S. 692 (1981) — Supreme Court of the United States
Facts
Officers arrived to execute a search warrant for drugs at a house and encountered Summers descending the front steps. They detained him, executed the warrant, found drugs, and discovered Summers had a prior drug conviction. He was then arrested. Summers challenged the detention as unlawful.
Issue
Whether officers executing a search warrant for contraband may detain the occupants of the premises during the search without individualized probable cause to arrest them.
Holding
Yes; the detention of occupants during execution of a search warrant for contraband is constitutionally reasonable even without probable cause to arrest.
Rule / Doctrine
A search warrant for contraband carries with it the limited authority to detain the occupants of the premises while the search is conducted. Three interests justify this detention: preventing flight if incriminating evidence is found, minimizing risk of harm to officers, and facilitating the orderly completion of the search.
Significance
Created a categorical rule authorizing detention of residents during warrant execution without individualized suspicion, balancing law enforcement interests against the limited nature of the intrusion. The rule was extended and its geographic limits addressed in Bailey v. United States (2013).