In Michigan v. Summers, 452 U. S. 692 (1981), police officers were about to execute a search warrant for contraband on Summers' residence when he came out the front door and locked it. The officers required Summers to reenter the residence with them and forced him to remain in the house until the search was completed, and evidence establishing probable cause to arrest him was found. The issue before the Supreme Court was whether an initial detention (not based upon probable cause) pursuant to a search warrant, not an arrest warrant, violated the suspect's Fourth Amendment constitutional right to be free of unreasonable seizure of his person. The court held: "If the evidence that a citizen's residence is harboring contraband is sufficient to persuade a judicial officer that an invasion of the citizen's privacy is justified, it is constitutionally reasonable to require that citizen to remain while officers of the law execute a valid warrant to search his home. Thus, for Fourth Amendment purposes, we hold that a warrant to search for contraband founded on probable cause implicitly carries with it the limited authority to detain the occupants of the premises while a proper search is conducted." ( Michigan v. Summers, supra, 452 U.S. at pp. 704-705.) The Summers court explained detentions pursuant to search warrants may be justified in order to minimize the risk of harm to both the police and the occupants of the house, to prevent flight, and to promote an orderly investigation, which may be facilitated if the occupants of the house are present. ( Id. at pp. 702-703.) In Michigan v. Summers, just as officers were about to execute a warrant to search a house for narcotics, they saw defendant go out the front door of the house and proceed down the steps. When the officers asked for his assistance in opening the door, he replied that he could not because he left his keys inside, but he could ring someone over the intercom. Another occupant came to the door, but did not admit the police officers. As a result, the officers obtained entrance by forcing open the front door. Once inside, they detained defendant and several other occupants of the house while they conducted a search. After finding narcotics in the basement and determining that defendant was the owner of the house, officers arrested defendant, searched him, and found heroine in his jacket pocket. Summers at 693. The defendant moved to suppress the heroine, arguing that his initial detention was unlawful. Id. at 694. In Michigan v. Summers, the U. S. Supreme Court relied upon the fact that a warrant had been issued for the search of the house; that the "type of detention imposed here is not likely to be exploited by the officer or unduly prolonged in order to gain more information" and that the stigma is reduced as the detention was in the house of that person. The Court found legal justification in the prevention of flight and of minimizing risk to law enforcement officers. The Court reiterated several times the fact that the person detained would remain in his home while it was being searched; thus, the holding that for Fourth Amendment purposes "a warrant to search for contraband . . . implicitly carries with at the limited authority to detain the occupants of the premises while a proper search is conducted." The U. S. Supreme Court held that a warrant to search for contraband founded on probable cause carried with it the limited authority to detain the occupants of the premises while a proper search of the premises was conducted and reversed the holding of the Supreme Court of Michigan. In Michigan v. Summers, the U. S. Supreme Court held, inter alia: If the evidence that a citizen's residence is harboring contraband is sufficient to persuade a judicial officer that an invasion of the citizen's privacy is justified, it is constitutionally reasonable to require that citizen to remain while officers of the law execute a valid warrant to search his home. Thus, for Fourth Amendment purposes, we hold that a warrant to search for contraband founded on probable cause implicitly carries with it the limited authority to detain occupants of the premises while a proper search is conducted. Id. at 704-705. In Michigan v. Summers, the Supreme Court of the United States recognized that "a warrant to search for contraband founded on probable cause implicitly carries with it the limited authority to detain the occupants of the premises while a proper search is conducted." Id. at 705. Among various "legitimate law enforcement interests" in such detention, the Court noted the "importance . . . of minimizing the risk of harm to the officers," noting "the execution of a warrant to search for narcotics . . . may give rise to sudden violence or frantic efforts to conceal or destroy evidence," circumstances that require "unquestioned command of the situation" to protect both police and occupants. Id. at 702-03. In Michigan v. Summers, the United States Supreme Court held that it was constitutionally permissible for police officers to detain the defendant, who was found descending the front steps of his dwelling, for purposes of conducting a search of the premises authorized by a valid search warrant. See id. at 704-05. In so holding, the Supreme Court found that the minor intrusiveness of detaining a resident in his home is outweighed by the law enforcement interests in: (1) preventing flight if incriminating evidence is found; (2) minimizing the risk of harm to the officers from violent occupants; (3) conducting an orderly search with the occupants' help in unlocking doors and containers. See id. at 701-03. The Court also observed that the existence of the search warrant provided an articulable and individualized suspicion which justified the "limited authority to detain the occupants at the premises." Summers, 452 U.S. at 705.