 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"