## Facts

- Los Angeles County sheriff’s deputies investigated a fraud and identity-theft ring involving several suspects, at least one of whom was recorded as owning a handgun.
- A deputy obtained a search warrant for two Lancaster, California residences and certain suspects, authorizing a search for documents and computer files; the warrant’s validity was not disputed.
- Unbeknownst to deputies, one targeted house had been sold months earlier to Max Rettele, who lived there with Judy Sadler and Sadler’s teenage son.
- Deputies executed the warrant early in the morning, entered a bedroom, and found Rettele and Sadler asleep and unclothed.
- Deputies ordered the two residents out of bed at gunpoint and required them to stand unclothed for a short period while the bedroom was secured.
- After ensuring no immediate threat and that no weapons were within reach, deputies allowed the residents to dress, completed a brief search, realized the suspects were not present, and left.
- No arrests were made and no contraband was found.

## Issues

1. Whether deputies executing a valid search warrant violate the Fourth Amendment by ordering unclothed occupants out of bed at gunpoint and briefly detaining them to secure the premises.
2. Whether discovering occupants whose race differs from the suspects named in the warrant requires officers to stop the search or end detention immediately.

## Decision

- The Supreme Court reversed the Ninth Circuit and reinstated summary judgment for the deputies and other defendants.
- The Court held the deputies’ conduct was objectively reasonable under the Fourth Amendment while executing a valid warrant.
- The Court rejected the view that a racial mismatch between occupants and suspects, by itself, made continued search and detention unreasonable.
- Because the Court found no constitutional violation, the deputies were entitled to judgment as a matter of law.

## Legal Principles

- Officers executing a valid search warrant may take reasonable steps to secure the premises and protect officer safety during the search, including briefly detaining occupants encountered inside.
- A temporary detention may remain reasonable even if it is uncomfortable or embarrassing, when closely tied to promptly securing the area and preventing access to weapons.
- The race of occupants, differing from that of suspects named in a warrant, does not alone negate the possibility that suspects are present elsewhere in the residence and does not automatically require cessation of the search.
- The Fourth Amendment analysis turns on objective reasonableness, including whether any intrusive conditions were prolonged beyond what safety and search needs required.

## Conclusion

The Court held that deputies executing a valid search warrant acted reasonably in briefly ordering unclothed residents out of bed and detaining them while securing the bedroom, and that the occupants’ race difference from the suspects did not itself require terminating the search or detention.


Los Angeles County v. Rettele, 550 U.S. 609 (2007)