Michigan v. Summers

The Court stated three reasons supporting the defendant’s detention:

1) The law enforcement interest in preventing flight in the event that incriminating evidence is found.

2) The interest in minimizing the risk of harm to the officers and occupants. The execution of a search warrant for narcotics is the kind of transaction that may give rise to sudden violence or frantic efforts to conceal or destroy evidence.

3) The orderly completion of the search may be facilitated if the residents are present, i.e. to open locked doors or locked containers to avoid the use of force that not only is damaging to property but may also delay the completion of the task at hand. Some seizures constitute such a limited intrusion of those detained and are justified by a substantial law enforcement interest that they may be supported on less than probable cause. The Court found this to be one of those occasions. The seizure here was reasonable under the Fourth Amendment.

NOTE: The Supreme Court held the government’s substantial interest was enhanced in this situation because the officers had a search warrant for a controlled substance. Some circuit courts (1st Circuit, 3rd Circuit, 4th Circuit and 11th Circuit) have extended the Summers doctrine to situations other than those that included controlled substances.