Facts
- Detroit police obtained a warrant to search George Summers’s house for narcotics.
- When officers arrived, Summers was descending the front steps of the home.
- Officers detained Summers, required him to reenter the house, and kept him there while they executed the search warrant.
- During the search, officers found narcotics in the basement and determined that Summers owned the house.
- Officers then arrested Summers and searched him incident to arrest, finding heroin in his coat pocket.
- Summers was prosecuted based on the heroin found on his person.
- Summers moved to suppress the heroin as the product of an unlawful seizure and search under the Fourth Amendment.
- The trial court suppressed the evidence and dismissed the case; Michigan appellate courts affirmed.
Issues
- Whether the Fourth Amendment permits officers executing a search warrant for contraband to detain an occupant of the premises during the search without independent probable cause to arrest.
- Whether evidence found during a search incident to an arrest that follows a lawful detention during warrant execution is admissible.
Decision
- The Supreme Court reversed, holding 6–3 (Justice Stevens) that a warrant to search for contraband based on probable cause implicitly authorizes limited detention of occupants while the search is conducted.
- The Court treated Summers as “seized” and assumed the initial detention lacked probable cause, but held it reasonable given the warrant and the limited nature of the restraint.
- The Court found the detention justified by interests in preventing flight if contraband is discovered, protecting officer safety during warrant execution, and permitting orderly completion of the search.
- Because the detention was lawful, Summers’s subsequent arrest (after contraband was found and his connection to the premises established) and the search incident to arrest were constitutional, making the heroin admissible.
Legal Principles
- A valid search warrant for contraband carries implicit, limited authority to detain occupants of the premises during execution of the warrant.
- The reasonableness of such detentions rests on the existence of a judicially authorized search and on law-enforcement interests: preventing flight, reducing risk of violence, and enabling efficient completion of the search.
- The authority is limited in scope and duration to the execution of the warrant; unusual circumstances or a prolonged detention may render a particular detention unreasonable.
- When a detention is lawful and probable cause to arrest later develops during the search, a subsequent arrest and search incident to arrest may yield admissible evidence.
Conclusion
The Court held that officers executing a contraband search warrant may temporarily detain occupants found at the premises during the search, and that evidence obtained from a later arrest and search incident to arrest is admissible when the initial detention is reasonable under the Fourth Amendment.