How have courts interpreted the "third interest" in a search warrant application?

The third interestofficer safetyis admittedly sometimes present in the arrest-warrant context as well. After all, co-occupants might frustrate the arrest of a family member or retaliate against officers if not properly restrained. But this lone interest cannot be enough to give officers the categorical power to detain home occupants during the execution of an arrest warrant irrespective of whether such a threat actually exists. The Summers Court relied on much more than that to give officers the "far-reaching authority" they now have to execute search warrants, Bailey v. United States , 568 U.S. 186, 133 S.Ct. 1031, 1039, 185 L.Ed.2d 19 (2013), so

[871 F.3d 915]

reliance on this factor alone is insufficient to extend the Summers rulea rule of categorical authorityto arrest warrants.