Summers rule (North Carolina) · Go Syfert
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Summers rule in North Carolina

6 North Carolina opinions name it 2 courts 2018–2022 3 in the last five years

The cases below were cited by North Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Bailey v. United Statesgreen
scotus · 2013 · cited in 5 North Carolina opinions naming this issue, 2018–2022
2 sentences

2022Ed. 2d 636 (2021). ¶ 32 This Court concluded in Wilson “that a person is an occupant for the purposes of the Summers rule if he ‘poses a real threat to the safe and efficient execution of a search warrant.’ ” 371 N.C. at 925 , 821 S.E.2d at 815 (quoting Bailey, 568 U.S. at 201 , 133 S. Ct. at 1042 ).

2022Ed. 2d 636 (2021). ¶ 32 This Court concluded in Wilson “that a person is an occupant for the purposes of the Summers rule if he ‘poses a real threat to the safe and efficient execution of a search warrant.’ ” 371 N.C. at 925 , 821 S.E.2d at 815 (quoting Bailey, 568 U.S. at 201 , 133 S. Ct. at 1042 ).

55
State v. Wilsongreen
nc · 2018 · cited in 5 North Carolina opinions naming this issue, 2019–2022
2 sentences

2022Ed. 2d 636 (2021). ¶ 32 This Court concluded in Wilson “that a person is an occupant for the purposes of the Summers rule if he ‘poses a real threat to the safe and efficient execution of a search warrant.’ ” 371 N.C. at 925 , 821 S.E.2d at 815 (quoting Bailey, 568 U.S. at 201 , 133 S. Ct. at 1042 ).

2022Ed. 2d 636 (2021). ¶ 32 This Court concluded in Wilson “that a person is an occupant for the purposes of the Summers rule if he ‘poses a real threat to the safe and efficient execution of a search warrant.’ ” 371 N.C. at 925 , 821 S.E.2d at 815 (quoting Bailey, 568 U.S. at 201 , 133 S. Ct. at 1042 ).

55
Michigan v. Summersgreen
scotus · 1981 · cited in 2 North Carolina opinions naming this issue, 2018–2019
2 sentences

2019The United States Supreme Court adopted the Summers rule based in part upon the rationale that “[i]f the evidence that a citizen’s residence is harboring contraband is sufficient to persuade a judicial officer that an invasion of the citizen’s privacy is justified, it is constitutionally reasonable to require that citizen to remain while officers of the law execute a valid warrant to search [her] home.” Summers, 452 U.S. at 704-05 , 69 L.

2019The United States Supreme Court adopted the Summers rule based in part upon the rationale that “[i]f the evidence that a citizen’s residence is harboring contraband is sufficient to persuade a judicial officer that an invasion of the citizen’s privacy is justified, it is constitutionally reasonable to require that citizen to remain while officers of the law execute a valid warrant to search [her] home.” Summers, 452 U.S. at 704-05 , 69 L.

12
Muehler v. Menagreen
scotus · 2005 · cited in 1 North Carolina opinions naming this issue, 2018–2018
2 sentences

2018Based on this doctrinal trilogy, we can identify three parts of the Summers rule: "a warrant to search for contraband founded on probable cause implicitly carries with it the limited authority to detain [ (1) ] the occupants," Summers , 452 U.S. at 705 , 101 S.Ct. at 2595 , (2) who are "within the immediate vicinity of the premises to be searched," Bailey , 568 U.S. at 201 , 133 S.Ct. at 1042 , and (3) who are present "during the execution of a search warrant," id. at 194 , 133 S.Ct. at 1038 (citing Summers , 452 U.S. at 702 -03 , 101 S.Ct. at 2594 ); see also Muehler , 544 U.S. at 102 , 125 S

2018Based on this doctrinal trilogy, we can identify three parts of the Summers rule: "a warrant to search for contraband founded on probable cause implicitly carries with it the limited authority to detain [ (1) ] the occupants," Summers , 452 U.S. at 705 , 101 S.Ct. at 2595 , (2) who are "within the immediate vicinity of the premises to be searched," Bailey , 568 U.S. at 201 , 133 S.Ct. at 1042 , and (3) who are present "during the execution of a search warrant," id. at 194 , 133 S.Ct. at 1038 (citing Summers , 452 U.S. at 702 -03 , 101 S.Ct. at 2594 ); see also Muehler , 544 U.S. at 102 , 125 S

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
State v. Thompson neutral
nc · 2019
2 sentences

2020App. 101 , 832 S.E.2d 510 (2019), on remand from our Supreme Court in light of its decision in Wilson, see State v. Thompson, 372 N.C. 48 , 822 S.E.2d 616 (2019) (per curiam), this Court further clarified who constitutes an “occupant” for purposes of the Summers rule.

2020App. 101 , 832 S.E.2d 510 (2019), on remand from our Supreme Court in light of its decision in Wilson, see State v. Thompson, 372 N.C. 48 , 822 S.E.2d 616 (2019) (per curiam), this Court further clarified who constitutes an “occupant” for purposes of the Summers rule.

12020–2020
State v. Austin green
nc · 1987
2 sentences

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

12018–2018
Terry v. Ohio green
scotus · 1968
2 sentences

2018In Terry v. Ohio , the Supreme Court determined that a brief stop and frisk did not violate a defendant's Fourth Amendment rights when "a reasonably prudent man would have been warranted in believing [the defendant] was armed and thus presented a threat to the officer's safety while he was investigating his suspicious behavior." 392 U.S. at 28 , 88 S.Ct. at 1883 .

2018In Terry v. Ohio , the Supreme Court determined that a brief stop and frisk did not violate a defendant's Fourth Amendment rights when "a reasonably prudent man would have been warranted in believing [the defendant] was armed and thus presented a threat to the officer's safety while he was investigating his suspicious behavior." 392 U.S. at 28 , 88 S.Ct. at 1883 .

12018–2018
State v. Davis green
nc · 2010
2 sentences

2018In fact, the order demonstrates that the Summers issue was not "raised and passed on by the trial court." Davis , 364 N.C. at 301 , 698 S.E.2d at 67 (quoting Tirado , 358 N.C. at 571 , 599 S.E.2d at 529 ).

2018In fact, the order demonstrates that the Summers issue was not "raised and passed on by the trial court." Davis , 364 N.C. at 301 , 698 S.E.2d at 67 (quoting Tirado , 358 N.C. at 571 , 599 S.E.2d at 529 ).

12018–2018
State v. Tirado green
sc · 2004
2 sentences

2018Davis , 364 N.C. at 301 , 698 S.E.2d at 67 (quoting Tirado , 358 N.C. at 571 , 599 S.E.2d at 529 ).

2018In fact, the order demonstrates that the Summers issue was not "raised and passed on by the trial court." Davis , 364 N.C. at 301 , 698 S.E.2d at 67 (quoting Tirado , 358 N.C. at 571 , 599 S.E.2d at 529 ).

12018–2018
Richardson v. United States green
scotus · 1987
2 sentences

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

12018–2018
Solek v. New Jersey Department of Public Advocate green
scotus · 1987
2 sentences

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

12018–2018
Austin v. North Carolina green
scotus · 1987
2 sentences

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

2018Finally, in my view our decision in State v. Austin does not stand for the principle that the State, as an appellee before the Court of Appeals, can bring an unpreserved constitutional issue for the first time on appeal. 320 N.C. 276 , 357 S.E.2d 641 , cert. denied, 484 U.S. 916 , 108 S.Ct. 267 , 98 L.Ed.2d 224 (1987). **929 Concerning the application of Summers to the facts of this case, I fully agree with Justice Beasley's concurring opinion that *818 "[b]ecause the instant case is fully resolved by application of the familiar and well-settled Terry standard, I would not extend the Summers r

12018–2018
State v. Tirado green
nc · 2004
2 sentences

2018Davis , 364 N.C. at 301 , 698 S.E.2d at 67 (quoting Tirado , 358 N.C. at 571 , 599 S.E.2d at 529 ).

2018In fact, the order demonstrates that the Summers issue was not "raised and passed on by the trial court." Davis , 364 N.C. at 301 , 698 S.E.2d at 67 (quoting Tirado , 358 N.C. at 571 , 599 S.E.2d at 529 ).

12018–2018

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 15A-256 (4) NC § N.C. Gen. Stat. § 15A-401 (4) NC § N.C. Gen. Stat. § 7A-30 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 7 (1986–2012) NC 6 (2018–2022) IN 6 (1990–2016) CA 5 (1981–1996) NM 4 (1989–2025) PA 4 (1994–2018) WA 4 (2002–2024) OK 3 (1994–2019) MN 2 (1994–1999) AZ 2 (1996–2015) GA 2 (2000–2015) NJ 2 (2020–2023) KS 2 (2000–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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