The following excerpt is from Perez Cruz v. Barr, 926 F.3d 1128 (9th Cir. 2019):
5 Alexander held that officers were not entitled to rely on Summers to detain individuals during the execution of an "administrative inspection warrant," reasoning that "[m]any of [Summers s justifications] simply do not hold true when the underlying warrant is an administrative warrant rather than a criminal search warrant." 29 F.3d at 1363. Similarly, Sharp v. County of Orange , 871 F.3d 901 (9th Cir. 2017), held that Summers does not provide "the categorical authority to detain co-occupants of a home incident to the in-home execution of an arrest warrant." Id. at 915 (emphasis omitted).
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