He moved to suppress the evidence based on his unlawful detention after he had already left his apartment. The trial court rejected that motion, holding that the detention was justified under "Michigan v. Summers". The defendant was convicted and, on appeal, the United States Court of Appeals for the Second Circuit agreed. In "Michigan v. Summers", 452 U.S. 692 (1981), the Court adopted the categorical rule that officers executing a search warrant for contraband may detain the occupants of the premises while the search is conducted. In the ruling, three justifications were identified for detaining occupants while executing a search warrant: (1) the legitimate law enforcement interest in preventing flight in the event that incriminating evidence is found, (2) the interest in minimizing the risk of harm to the officers, and (3) the orderly completion of the search, which may be facilitated if the occupants of the premises are present. This case presents the question whether the rule of Summers extends to the detention of a former occupant who has left the immediate vicinity of the premises before the warrant is executed. Multiple scholars have questioned the efficacy of applying "Michigan v. Summers" to individuals who have departed the premises being searched. One commentator, in examining the application of "Michigan v. Summers" over the course of thirty years, acknowledged the lack of clarity in the Supreme Court's original decision as to whether the categorical rule that occupants may be detained applies to "recent occupants":  He argues that this is one way in which the rule from "Michigan v. Summers" has been "extended well beyond what the Court’s initial rationale should reasonably allow" and, as a result, has "put at risk the very liberty interests that it was designed to protect." In a 6–3 decision, the Court reversed and remanded the Second Circuit Court's ruling, stating that it was an unreasonable seizure under the Fourth Amendment. Writing for the majority, Justice Kennedy agreed that the" Michigan v. Summers "ruling was broad enough to cover the pursuit and detention of a suspect who had left the scene. However, because none of the law-enforcement interests the earlier holding identified were involved, officers did not have probable cause in this case to detain the suspects a mile away from the scene before the apartment was searched, and it thus added an additional level of intrusiveness: "As demonstrated here, detention beyond the immediate vicinity can involve an initial detention away from the scene and a second detention at the residence. In between, the individual will suffer the additional indignity of a compelled transfer back to the premises".