Bailey v. United States, 133 S. Ct. 1031

Police obtained a warrant to search a basement apartment at 103 Lake Drive for a .380 handgun on July 28, 2005.
Two detectives observed two men matching the informant’s description leave the premises and follow them after signaling intent to detain departing occupants.
Bailey and Middleton were detained a distance away from the premises, in a parking lot, after a brief vehicle stop and patdown.
A gun and drugs were later found inside the apartment during the search; Bailey’s keys were seized and one opened the door to the basement unit.
Bailey was charged with possession with intent to distribute cocaine, felon in possession of a firearm, and possession of a firearm in furtherance of a drug offense; Bailey moved to suppress the key and statements; the district court denied suppression; the court of appeals affirmed Summers-based detention ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Summers authorizes detention beyond immediate vicinity of the searched premises.	Bailey contends Summers allows detentions only at or near the premises.	Government argues Summers extends to departures from premises to ensure search integrity.	Summers does not authorize distant detentions; must be within immediate vicinity.
Whether the safety, flight, and efficiency rationales justify detaining a departing occupant away from the scene.	Bailey’s departure before the search negates necessity for detention away from the scene.	Detention serves officer safety, search efficiency, and flight prevention.	None of Summers’ interests justify detaining beyond the immediate vicinity.
Whether Terry or probable cause could justify the later stop/detention of Bailey.	Detention should be excused only by Summers or Terry with reasonable suspicion.	Alternative Terry stop or probable cause could validate later detention.	The majority remands to determine if Terry stop information justified later detention.
Is the Summers framework misapplied by using a case-by-case balancing approach instead of a categorical rule?	Court of Appeals used multi-factor balancing to sustain detention.	Detention should be governed by Summers’ categorical rule.	Summers creates a categorical rule limited to occupants within the immediate vicinity.

Michigan v. Summers, 452 U.S. 692 (1981) (detention of occupants incident to a valid search is permissible)
Muehler v. Mena, 544 U.S. 93 (2005) (detention is permissible to secure the premises during a search)
Dunaway v. New York, 442 U.S. 200 (1979) (probable cause required for most seizures; Summers is a narrow exception)
Florida v. Royer, 460 U.S. 491 (1983) (limits on stop and detention; reasonableness requires tailored approach)