Does the Summers rule apply to arrest warrants?

Search warrants and arrest warrants are meaningfully different because they protect different Fourth Amendment interests. See Steagald v. United States , 451 U.S. 204, 21213, 101 S.Ct. 1642, 68 L.Ed.2d 38 (1981) (finding that an arrest warrant is not sufficient to enter a third party's home to arrest a subject, and that a separate search warrant must be obtained for that purpose).⁸ So it is not appropriate to assume that the rules of search warrants automatically apply to those of arrest warrants. We therefore conduct an independent analysis to determine whether the Summers rule encompasses arrest warrants.