The U.S. Supreme Court case Chunon L. Bailey, aka Polo, Petitioner v. United States (2012) revolved around the question of whether police can detain an individual away from their residence while a search warrant is being executed at that location. The petitioner, Chunon Bailey was detained about a mile away from his home after leaving it shortly before the execution of a search warrant for firearms and drugs in his apartment by law enforcement officers. He was later charged with drug and firearm offenses based on evidence found during this search operation. Bailey argued that his detention violated the Fourth Amendment's prohibition against unreasonable seizures because he had left the immediate vicinity of his home before the police began their search operation. However, in its decision issued on February 19th 2013, The Supreme Court ruled against Bailey stating that detaining him did not violate any constitutional rights under these circumstances as long as there were reasonable grounds to believe he posed a threat to officers or could potentially destroy evidence if allowed to remain free.

In the dissenting opinion for Chunon L. Bailey, AKA Polo, Petitioner v. United States (2012), Justice Breyer argued that the majority's decision was too restrictive and could potentially hinder law enforcement efforts in certain situations. He believed that police should have more leeway to detain an individual away from their residence during a search warrant execution if there is reasonable suspicion of criminal activity or potential danger to officers. According to Justice Breyer, the majority’s interpretation of Michigan v Summers did not adequately consider these factors and instead focused solely on geographical proximity between detention and searched premises which he considered as overly narrow approach.