Michigan v. Summers - Impact

The Court's decision in Summers constituted a significant expansion of the situations in which police officers may detain a person even though they do not have probable cause to do so. The Court has continued this expansion after Summers, in conjunction with recognizing more exceptions to the warrant requirement of the Fourth Amendment. Thus, the Court's decision in Summers fostered a growing number of situations in which police may conduct searches of property and seizures of persons outside of the requirements of the Fourth Amendment.