## Facts

- Police investigated a gang-related drive-by shooting and believed an armed gang member lived at a residence in Simi Valley, California.
- Officers obtained a warrant to search the house and premises for deadly weapons and evidence of gang membership.
- Early in the morning, a SWAT team entered the residence; Iris Mena, an occupant, was handcuffed at gunpoint in her bedroom.
- Mena and three other individuals were moved to a converted garage and kept handcuffed under guard for about two to three hours while the search was conducted.
- During the detention, an immigration officer, using a local officer as interpreter, questioned Mena about her immigration status.
- Mena sued under 42 U.S.C. § 1983, alleging Fourth Amendment violations based on the duration and manner of her detention and the immigration questioning.

## Issues

1. Whether detaining an occupant in handcuffs for two to three hours during execution of a valid search warrant violated the Fourth Amendment.
2. Whether questioning an occupant about immigration status during that detention required independent reasonable suspicion under the Fourth Amendment.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit.
- Detaining Mena for the duration of the search was reasonable under the categorical authority to detain occupants during a lawful search-warrant execution.
- The use of handcuffs was reasonable force in light of the high-risk circumstances, including suspected armed gang involvement and the need to control multiple occupants.
- The two-to-three-hour handcuffed detention did not become unreasonable given continuing safety concerns during the search.
- Questioning Mena about immigration status did not create a separate Fourth Amendment violation because mere questioning is not a seizure and the questioning did not prolong the lawful detention.

## Legal Principles

- Officers executing a valid search warrant may detain occupants of the premises for the duration of the search.
- Authority to detain incident to a search includes authority to use objectively reasonable force to effectuate the detention.
- The reasonableness of force used during a detention is assessed under an objective Fourth Amendment standard that weighs governmental interests, including officer and occupant safety.
- Mere police questioning, without more, does not constitute a separate Fourth Amendment seizure.
- During a lawful detention, officers need not have independent reasonable suspicion for each question, so long as questioning does not prolong the detention or otherwise make it unreasonable.

## Conclusion

The Court held that officers lawfully executing a search warrant may detain occupants in handcuffs for the search’s duration when objectively reasonable for safety and control, and may question detainees about immigration status without separate suspicion if the questioning does not extend the detention.


Muehler v. Mena, 544 U.S. 93 (2005)