Muehler v. Mena

PETITIONER: Darin L. Muehler, et al.
RESPONDENT: Iris Mena
LOCATION: City of New London Town Hall

DOCKET NO.: 03-1423
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 544 US 93 (2005)
GRANTED: Jun 14, 2004
ARGUED: Dec 08, 2004
DECIDED: Mar 22, 2005

ADVOCATES:
Carter G. Phillips - argued the cause for Petitioners
James I. Crowley - for the National League of Cities et al. as amici curiae urging reversal
Kannon K. Shanmugam - argued the cause for Petitioners, on behalf of the United States, as amicus curiae
Paul L. Hoffman - argued the cause for Respondent
Richard Ruda - for the National League of Cities et al. as amici curiae urging reversal

Facts of the case

Police detained Mena and others in handcuffs while they searched the house they occupied. During the detention they asked Mena about her immigration status. The police had a search warrant to search the premises for deadly weapons and evidence of gang membership. Mena sued the officers in federal district court for violating her Fourth Amendment right to be free from unreasonable seizure. The district court ruled for Mena. The Ninth Circuit affirmed, holding that using handcuffs to detain Mena during the search violated the Fourth Amendment and that the officers' questioning of Mena about her immigration status also violated the Fourth Amendment.

Question

(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?

Media for Muehler v. Mena

Audio Transcription for Oral Argument - December 08, 2004 in Muehler v. Mena

Audio Transcription for Opinion Announcement - March 22, 2005 in Muehler v. Mena

William H. Rehnquist:

I have the opinion of the Court to announce in No.03-1423, Muehler against Mena.

During a search of the premises occupied by respondent, she was detained and handcuffs and questioned about her immigration status.

The Court of Appeals for the Ninth Circuit found that the use of handcuffs and the questioning violated the Fourth Amendment rights.

We granted certiorari and now reverse.

First, Mena's disambient was plainly permissible under our opinion in Michigan against Summers, and the use of handcuffs to effectuate the detention was reasonable.

Second, the officer’s questioning of Mena did not violate the Fourth Amendment because it was not an independent seizure.

The judgment of the Court of Appeals is vacated and the case remanded for further proceedings consistent with this opinion.

Justice Kennedy has filed a concurring opinion; Justice Stevens filed an opinion concurring in the judgment in which Justices Souter, Ginsburg, and Breyer join.