Bailey v. United States

Summary

The Court held that the categorical authority to detain occupants during execution of a search warrant does not extend to a person stopped nearly a mile from the premises after departing. Because Bailey's detention was outside the immediate vicinity and was more intrusive than a detention at the search scene, it could be justified only by another Fourth Amendment basis, such as reasonable suspicion or probable cause. The judgment was reversed and remanded for consideration of the unresolved Terry issue. Justice Scalia concurred to emphasize the categorical nature of the rule, while Justice Breyer, dissenting, would have upheld the detention under a reasonably practicable standard based on safety, flight, and evidence-preservation concerns.