Michigan v. Summers

Police arriving to execute a valid warrant to search Summers's (defendant) house for contraband encountered him walking down the front steps; he let them in, and once officers found drugs inside, they arrested him. Officers found heroin on Summers and detained him for the remainder of the search. Summers argued that his detention during the search, before any independent finding of probable cause to arrest him personally, was unconstitutional and sought to suppress the heroin as its fruit.