Bailey v. United States
In brief
The Supreme Court said the warrant-based rule did not cover Bailey's detention, overturned the Second Circuit's decision, and sent the case back.
- Where it stands
- Decided
Decided 6-3 · February 19, 2013 · Opinion by Justice Scalia
- What it’s about
- Suffolk County officers detained Chunon Bailey away from his apartment as they prepared to execute a search warrant.
- Who it affects
- The ruling means the officers could not use the search-warrant detention rule to justify stopping Bailey beyond the immediate vicinity of his apartment.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the warrant-based detention rule applies only within the immediate vicinity of the place being searched, overturned the Second Circuit’s decision, and sent the case back to the lower court (remanded).
Justice Breyer's dissent described officers following Bailey and another man for 0.7 miles before stopping them.
Under Michigan v. Summers, officers may detain occupants while carrying out a valid warrant to search their home.
Question presented
Did Suffolk County police officers lawfully detain Bailey incident to the execution of a search warrant when officers saw Bailey leaving the immediate vicinity of his apartment before they executed the warrant?
What the Court decided
Holding
The rule in Summers is limited to the immediate vicinity of the premises to be searched and does not apply here, where Bailey was detained at a point beyond any reasonable understanding of the immediate vicinity of the premises in question. Pp. 4 − 15. 652 F. 3d 197, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court limited the warrant-based detention rule to people stopped close to the place being searched (within its immediate vicinity). It said Bailey was stopped beyond any reasonable understanding of that area.
The vote
From the opinions
“In light of the risks of flight, of evidence destruction, and of human injury present in this and similar cases, I would follow the approach of the Court of Appeals and uphold its determination.”
What's next
The case returns to the Second Circuit for further proceedings under the Supreme Court's ruling.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Bailey
Opinion added: Bailey
More questions
- Why did Justice Breyer disagree?
- He argued that risks of flight, evidence destruction, and injury supported the Second Circuit's decision to uphold the detention.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.