Fields v. State

In Michigan v. Summers, 452 U.S. 692, 705, 101 S.Ct. 2587, 69 L.Ed.2d 340 (1981), the Supreme Court held that police officers executing a search warrant acted reasonably in temporarily detaining the occupant of the premises while the search was conducted. The principal issue in this case is whether the Michigan v. Summers analysis applies when police officers detain a non-occupant who approaches the premises while the search is underway.

After a jury trial in the Circuit Court of Baltimore County, Devin Jermaine Fields was convicted of possession of cocaine with intent to distribute, a…