The following excerpt is from United States v. Weaver, 18-1697-cr (2nd Cir. 2021):
[10] To be sure, an additional intrusion such as an order to spread eagle or even handcuffing may be permissible without suspicion in other Fourth Amendment contexts, such as the execution of a valid search warrant. See Michigan v. Summers, 452 U.S. 692 (1981). But in that instance, the additional detention "represents only an incremental intrusion on personal liberty when the search of a home has been authorized by a valid warrant," and the existence of the search warrant itself "provides an objective justification for the detention. . . . [A] neutral magistrate rather than an officer in the field has made the critical determination that the police should be given a special authorization to thrust themselves into the privacy of a home." Id. at 703.
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