In the 1980 case Michigan v. Summers, the United States Supreme Court ruled that a search warrant implicitly carries with it the limited authority to detain occupants of premises while a proper search is conducted. The case arose when police officers, executing a search warrant for narcotics at George Summers' house in Detroit, detained him upon his arrival home during their investigation. They found drugs on his person and arrested him for possession. Summers argued this detention was an unreasonable seizure under the Fourth Amendment. The court disagreed with Mr. Summers and held that such detentions are reasonable under certain circumstances due to law enforcement's interest in preventing flight should incriminating evidence be found; minimizing risk of harm to officers; and facilitating orderly completion of searches by preventing interference from detainees or others present on site. This decision established precedent allowing police to detain individuals present at locations being searched pursuant to valid warrants without violating constitutional protections against unreasonable seizures.

In the dissenting opinion for Michigan v. Summers, Justice Stewart, joined by Justices Brennan and Marshall, argued that detaining a person without a warrant or probable cause is unconstitutional under the Fourth Amendment. They disagreed with the majority's view that such detention was reasonable due to its minimal intrusion on personal liberty and its potential benefits to law enforcement officers. The dissenting justices believed this reasoning dangerously expanded police powers beyond constitutional limits. They emphasized that any detention constitutes a significant deprivation of liberty and should not be taken lightly. Furthermore, they contended there were other less intrusive means available for ensuring officer safety and preventing flight from justice during search warrants execution.