Welshman v. Commonwealth
In Welshman v. Commonwealth, 28 Va. App. 20, 30, 502 S.E.2d 122, 127 (1998), the Court noted the Summers Court held "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.
The Court also recognized that "although the Court stressed the importance of the existence of the search warrant to justify the detention in that case, it also noted its holding did not 'preclude the possibility that comparable police conduct may be justified by exigent circumstances in the absence of a warrant.'" Id. at 31, 502 S.E.2d at 127.