Michigan v. Summers
In Michigan v. Summers, 452 U.S. 692, 705 (1981), the U.S. Supreme Court held that officers executing a search warrant for contraband may "detain the occupants of the premises while a proper search is conducted."
In weighing whether the search in Summers was reasonable the Court first found that "detention represents only an incremental intrusion on personal liberty when the search of a home has been authorized by a valid warrant." Id. at 703. Against that interest, it balanced "preventing flight in the event that incriminating evidence is found"; "minimizing the risk of harm to the officers"; and facilitating "the orderly completion of the search." Id. at 702-703; see Muehler v. Mena, 544 U.S. 93 (2005).
In executing a search warrant officers may take reasonable action to secure the premises and to ensure their own safety and the efficacy of the search. Id. at 98-100.
The test of reasonableness under the Fourth Amendment is an objective one.