State v. Rolon

Summary

The court held that the warrantless detention of the defendant during execution of a search warrant was not justified because the state failed to establish that he was in the immediate vicinity of the apartment being searched. The record lacked evidence addressing the location's lawful limits, line of sight, and ease of reentry, and the court rejected a generalized reasonableness balancing approach. The judgment was reversed and the case remanded with instructions to grant the motion to suppress.