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Muehler v. Mena

Docket No.: 03-1423
Certiorari Granted: Jun 14 2004
Argued: December 8, 2004
Decided: March 22, 2005


Amendment 4: Fourth Amendment, Criminal Procedure, Search and Seizure, Fifth Amendment, Fourth Amendment, Immigration and Naturalization, Internal Revenue Code, Medicare, Sixteenth Amendment, Takings Clause, immigration, privacy, probable cause, qualified immunity

PartyNames: Darin L. Muehler, et al. v. Iris Mena
Petitioner: Darin L. Muehler, et al.
Respondent: Iris Mena

Court Below: United States Court of Appeals for the Ninth Circuit
Citation: 226 F3d 1031
Supreme Court Docket

Darin L. Muehler, et al.
Iris Mena
544 U.S. 93 (2005)
Question Presented:

1. Whether, in light of this Court's repeated holdings that mere police questioning does not constitute a seizure, the Ninth Circuit erred in ruling that law enforcement officers who have lawfully detained an individual pursuant to a valid search warrant engage in an additional, unconstitutional "seizure" if they ask that person questions about criminal activity without probable cause to believe that the person is or has engaged in such activity. 2. Whether, in light of this Court's ruling in Michigan v. Summers, 452 U.S. 692 (1981), that a valid search warrant carries with it the implicit authority to detain occupants while the search is conducted, the Ninth Circuit erred in ruling that a two to three hour detention of the occupant of a suspected gang safe-house while officers searched for concealed weapons and other evidence of a gang-related drive-by shooting was unconstitutional because the occupant was initially detained at gunpoint and handcuffed for the duration of the search.


(1) Did police violate the Fourth Amendment right to be free from unreasonable seizure by detaining Mena in handcuffs for 2-3 they executed a search warrant for contraband on the premises she occupied? (2) Did police violate the Fourth Amendment by questioning Mena about her immigration status during the detention?

Muehler v. Mena

December 8, 2004

Holding: vacated and remanded
Decision: Decision: 9 votes for Muehler, 0 vote(s) against
Vote: 9-0

Muehler v. Mena
Case Documents

1Opinion in Muehler v. Mena
2Opinion in Muehler v. Mena
3Slip Opinion in Muehler v. Mena
Additional documents for this case are pending review.