In Michigan v. Summers, 452 U.S. 692, 704–05 (1981), this Court held that pursuant to a lawfully executed search warrant, officers have a limited authority to detain an individual during the search. However, this Court did not address the issue of custodial interrogation during such a detention. See United States v. Kim, 292 F.3d 969, 976 (CA9 2002). This Court also has not provided "criteria for identifying "special circumstances" for determining when a detention is "prolonged"; in particular, it fails to tell law enforcement officers whether a detention will always be permissible, however protracted, so as it does not exceed the length of the search ***." See Summers, 452 U.S. at 712 (Stewart J. dissenting, Brennan and Marshall JJ., joined). This case tests whether federal agents exceeded this limited authority when they detained and then interrogated the target of a search warrant for one hour and forty-minutes without reading him his rights pursuant to Miranda v. Arizona by presenting the following questions:

1. Whether police officers executing a search warrant must provide Miranda warnings to an individual who is detained pursuant to the search warrant and interrogated?

2. What are the criteria for identifying "special circumstances" or for determining when a detention is "prolonged" in relation to a search warrant detention?

Whether police officers executing a search warrant must provide Miranda warnings during a detention and what criteria determine when such a detention becomes 'prolonged'