United States v. Prentiss Watson, 2013 U.S. App. LEXIS 30

Watson worked in a Baltimore convenience store located in a building to be searched for drugs; he lived in a second-floor room.
Detectives surveilled the block for drug activity, arrested a resident who led to a search warrant for the building, and secured the building to prevent evidence destruction.
Watson and the store owner Steele were detained for about three hours inside the store after being advised of Miranda rights, without being told they could leave.
Detective Jamison obtained a search warrant; during the search, a shotgun, revolver, and ammunition were found, and Watson admitted something about the revolver.
Watson was charged with being a felon in possession of a firearm and ammunition; he moved to suppress his post‑detention statement, which the district court denied, and he was convicted after a four‑day trial.
On appeal, the Fourth Circuit vacated and remanded, holding the three‑hour detention unlawful, the taint of the arrest could not be purged, and the statement was improperly admitted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Watson was seized under the Fourth Amendment	Watson argues detention without probable cause violated Fourth Amendment.	Watson contends the long detention was unlawful; government asserts Summers/McArthur justify detention.	Watson was seized and the detention was unlawful.
Whether the three-hour detention was reasonable under the Fourth Amendment	Detention was excessive and unsupported by probable cause or exigent circumstances.	Detention was necessary to secure the scene and prevent evidence loss during warrant processing.	Detention was unreasonable and unlawful.
Whether Watson's incriminating statement was tainted by the unlawful detention	Statement should be suppressed as the product of an illegal arrest.	Warnings and intervening events break the causal chain; statement should be admissible.	Statement was the product of unlawful arrest; suppression required.
Whether the erroneous admission of the statement was harmless	Erroneous admission could be harmless due to other evidence.	Without the statement, the verdict could differ given weak direct evidence of possession.	Admission was not harmless beyond a reasonable doubt.
What is the proper remedy for the constitutional error	Convictions should be vacated and remanded for new proceedings.	No alternative remedy discussed beyond discharge of tainted evidence.	Convictions vacated and case remanded for further proceedings.

Illinois v. McArthur, 531 U.S. 326 (U.S. 2001) (temporary seizure; reasonableness with probable cause and safety)
United States v. Summers, 452 U.S. 692 (U.S. 1981) (detention of occupants during a search with probable cause; implicit authority to detain)
Maryland v. Buie, 494 U.S. 325 (U.S. 1990) (protective sweeps; officer safety and scope of intrusion)
Brown v. Illinois, 422 U.S. 590 (U.S. 1975) (extraction of confessions after unlawful arrest; limited break in taint factors)
Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (causal chain and fruit of the poisonous tree; break requirements)
Kaupp v. Texas, 538 U.S. 626 (U.S. 2003) (confession after unlawful arrest;break in taint considerations)
United States v. Cephas, 254 F.3d 488 (4th Cir. 2001) (exigent circumstances; warrantless entry; occupancy detention)
United States v. Ruiz-Estrada, 312 F.3d 398 (8th Cir. 2002) (detention of occupants during warrant process; securing premises)
United States v. Limares, 269 F.3d 794 (7th Cir. 2001) (detention of occupants during warrant preparation)
United States v. Photogrammetric Data Servs., Inc., 259 F.3d 229 (4th Cir. 2001) (detention of employees pending search pursuant to warrant)
Muehler v. Mena, 544 U.S. 93 (U.S. 2005) (three-hour detention during search; Summers applied)
Summers (Bootstrapped in context here), none (U.S. 1981) (See Summers for framework; not an official reporter entry here)