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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 '''''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."
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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).
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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.
 
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.
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