The following excerpt is from U.S. v. Winsor, 816 F.2d 1394 (9th Cir. 1987):
The circumstances existing following the entry by the police required a brief but complete foreclosure of appellant's freedom to leave his hotel room. See Michigan v. Summers, 452 U.S. 692, 101 S.Ct. 2587, 69 L.Ed.2d 340 (1981) (upholding the detention of the occupants of a private dwelling while the police conducted a lawful search of the premises). The police could lawfully detain appellant while effecting the arrest of his brother, a potentially dangerous felon, and the search incident to that arrest.
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2. Threat of Arrest
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