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Muehler v. Mena

United States Supreme Court
544 U.S. 93 (2005)



Officers Darren Muehler and Robert Brill (defendants) obtained a warrant to search for weapons and evidence of gang activity in the home of a gang member suspected of a drive-by shooting. On February 3, 1998, a Special Weapons and Tactics (SWAT) team secured the home and detained Iris Mena (plaintiff) and the other occupants at gunpoint. The occupants were handcuffed and held in the garage for two to three hours while the search was completed. Officers found weapons, drugs, and other evidence of gang activity. An Immigration and Naturalization Service (INS) Officer questioned the occupants and asked for immigration documentation. Mena filed suit in district court against Muehler and Brill under 42 U.S.C. § 1983 for violations of her constitutional rights. The jury found that the length of the detention and amount of force used were unreasonable and violated the Fourth Amendment and awarded Mena $60,000 in damages. The court of appeals affirmed, holding (1) that it was unreasonable to keep Mena handcuffed in the garage for the length of the search, (2) that Mena should have been released when it became apparent that she was not dangerous, and (3) that questioning Mena about her immigration status was also a violation of the Fourth Amendment. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Rehnquist, C.J.)

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