Muehler v. Mena

Summary

The Supreme Court held that officers executing a search warrant acted consistently with the Fourth Amendment in detaining occupant Iris Mena in handcuffs for the duration of the search, because the authority to detain occupants incident to a warranted search is categorical and the safety interests were at their maximum in a search of a suspected gang house for weapons; it further held that questioning Mena about her immigration status during that lawful detention was not an independent Fourth Amendment violation, since mere questioning is not a seizure and did not prolong the detention. The Court vacated the Ninth Circuit's contrary judgment and remanded, declining to address Mena's alternative contention that her detention outlasted the search. Justice Kennedy concurred, joining the opinion but warning that handcuffing during searches must not become routine or unduly prolonged. Justice Stevens, joined by Justices Souter, Ginsburg, and Breyer, concurred in the judgment, agreeing on the questioning issue but concluding the majority misapplied Graham's reasonableness test to the prolonged handcuffing and would have the Ninth Circuit test the sufficiency of the jury's verdict on remand.