Muehler v. Mena

In Muehler v. Mena, 544 U.S. 93 (2005), the U.S. Supreme Court held that detention of an immigrant in handcuffs, and questioning her, during the length of a search pursuant to a search warrant did not violate her Fourth Amendment rights. The Court found that this was consistent with its opinion in Michigan v. Summers, 452 U.S. 692 (1981).

Respondent Iris Mena was detained in handcuffs during a search of the premises that she and several others occupied. Petitioners were lead members of a police detachment executing a search warrant of these premises. She sued the officers under Rev Stat § 1979, 42 U.S.C. § 1983, and the District Court found in her favor. The Court of Appeals affirmed the judgment, holding that the use of handcuffs to detain Mena during the search violated the Fourth Amendment and that the officers' questioning of Mena about her immigration status during the detention constituted an independent Fourth Amendment violation. Mena v. Simi Valley, 332 F.3d 1255 (CA9 2003). The Supreme Court reversed.

Chief Justice William Rehnquist wrote the opinion for the unanimous Court, with four Justices in the liberal wing of the Court concurring separately.