In Muehler v. Mena (2005) 544 U.S. 93, the high court emphasized that "an officer's authority to detain incident to a search is categorical; it does not depend on the 'quantum of proof justifying detention or the extent of the intrusion to be imposed by the seizure.'" Accordingly, the court reversed the Ninth Circuit's conclusion in that case that "the officers should have released Mena (an occupant caught up in the execution of a search warrant) as soon as it became clear that she posed no immediate threat." (Id. at p. 97.) To the contrary, her "detention for the duration of the search was reasonable under Summers because a warrant existed to search the subject property and she was an occupant of that address at the time of the search." (Id. at p. 98.) But the court also stated explicitly what was implicit in Michigan v. Summers: an occupant's "lawful seizure" during a warrant-backed search "'can become unlawful if it is prolonged beyond the time reasonably required to complete that mission.'" (Mena, at p. 101.) The Court held that the plaintiff was properly detained as she was on the premises subject to the search warrant. Questions as to her immigration status did not prolong her detention and, therefore, there was no additional seizure within the meaning of the fourth amendment. Muehler, 544 U.S. at 100-01. Moreover, in Muehler, the Court chose not to address Ms. Mena's alternative argument, pertinent to this case, that her detention extended beyond the time the police completed the tasks incident to the search, because the court of appeals had not addressed it. Muehler, 544 U.S. at 102.