In Allen v. Commonwealth, 3 Va. App. 657, 353 S.E.2d 162 (1987), the officers had a search warrant for the home and detained the defendant for purposes of executing the warrant.
The Court held that the defendant's detention was permissible under the doctrine of Summers. See Allen, 3 Va. App. at 662, 353 S.E.2d at 165.
However, the defendant in that case was stopped by police in a van traveling along a single-lane driveway leading from the house. See id. at 659-60, 353 S.E.2d at 163-64.
The defendant had not yet left the curtilage. In addition, the defendant was aware that the police were about to search his residence and was, thus, a risk to flee or possibly destroy evidence if not detained.
Furthermore, the officers had earlier observed occupants of the premises to be in possession of shotguns. See id.