US Supreme Court Michigan v. Summers 79-1794

Decided June 22, 1981

   Police obtained a warrant to search Summers' home.  When they arrived, they found that he was just leaving.  He was detained, brought back into the house, and the search of the premises was conducted.  After incriminating evidence was found, Summers was arrested.  During a search incident to arrest, an envelope containing heroin was found in his pocket.  Summers was charged with possession of the heroin found on his person, but the court suppressed the evidence after finding that Summers' initial detention was unreasonable.  The prosecution appealed.

   The US Supreme Court reasoned that a search warrant is a finding by a detached magistrate that there is probable cause to believe that incriminating evidence will be found in a particular place, and that this sort of finding confers suspicion on the occupants of that same place.  This means that the police have the authority to detain people found on the premises where they execute a search warrant, which means that Summers' detention was reasonable.  The suppression was reversed.