Michigan v. Summers (1980)
- Docket
- 79-1794
- Decided
- 1980-01-01
Summary
Question: Did the officers have the authority under the Fourth Amendment to detain Summers while they executed a warrant to search his house for heroin and other contraband? Conclusion: Yes. Justice John Paul Stevens delivered the opinion of the 6-3 majority. The Court held that a warrant to search for contraband grants police officers the limited authority to detain occupants of a house during the search of the premises. This authority is an exception to the probable cause standard to determine the reasonableness of Fourth Amendment seizures. The law enforcement interests in preventing the flight of occupants of the property named in the search warrant, reducing the risk of harm to officers, and otherwise facilitating the search convinced the Court that the detention of people on the property in question was reasonable. Similarly, the Court held that the exception to the probable cause standard applied to Summers’ detention because it was less intrusive than an arrest and unlikely to be abused by police officers. Finally, the connection between an occupant and the home named in the search warrant gave the officers an easily identifiable and certain basis on which to detain Summers. Justice Potter Stewart wrote a dissenting opinion in which he criticized the Court for expanding the scope of the exception to the probable cause standard for Fourth Amendment seizures. Justice Stewart argued that the State failed to offer a justification for the detention that was unrelated to its interest in investigating crimes and apprehending suspects. He further expressed concern that the Court’s holding could be exploited by police officers eager to detain occupants and make them available for arrest in case the search of the property revealed evidence of criminal activity. Justice William J. Brennan, Jr. and Justice Thurgood Marshall joined in the dissent.