Darin L. Muehler, et al. v. Iris Mena (544 U.S. 93)

U.S. Supreme Court · decided March 22, 2005 · Supreme Court Database (Spaeth)

Citation
544 U.S. 93 · 125 S. Ct. 1465
Decided
March 22, 2005
Term
October Term 2004
Vote
9–0
Majority author
Justice Rehnquist
Issue area
Criminal Procedure
Disposition
Vacated and remanded
Outcome
Petitioning party won
Ideological direction
Conservative

Opinion excerpt

Chief Justice Rehnquist delivered the opinion of the Court. Respondent Iris Mena was detained in handcuffs during a search of the premises that she and several others occupied. Petitioners were lead members of a police detachment executing a search warrant of these premises. She sued the officers under Rev. Stat. § 1979, 42 U. S. C. § 1983, and the District Court found in her favor. The Court of Appeals affirmed the judgment, holding that the use of handcuffs to detain Mena during the search violated the Fourth Amendment and that the officers’ questioning of Mena about her immigration status during the detention constituted an independent Fourth Amendment violation. Mena v. Simi Valley, 332 F. 3d 1255 (CA9 2003). We hold that Mena’s detention in handcuffs for the length of the search was consistent with our opinion in Michigan v. Summers, 452 U. S. 692 (1981), and that the officers’ questioning during that detention did not violate her Fourth Amendment rights. * * * Based on information gleaned from the investigation of a gang-related, driveby shooting, petitioners Muehler and Brill had reason to believe at least one member of a gang — the West Side Locos — lived at 1363 Patricia Avenue. They also suspected that the individual was armed and dangerous, since he had recently been involved in the driveby shooting. As a result, Muehler obtained a search warrant for 1363 Patricia…

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