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Name: People v. Celis
Case #: S107885
Court: CA Supreme Court
District CalSup
Opinion Date: 07/26/2004

A defendant who was stopped and handcuffed outside of his home for a few minutes while police performed a sweep search of his home was detained, not arrested. However, the search of the house violated the Fourth Amendment because the officers lacked articulable facts to support a reasonable suspicion that the house harbored additional suspects who might pose a danger to officers. In regard to the first question, the court held that under the totality of the circumstances, including the fact that the defendant was suspected of having committed a felony, the officers did not convert the investigative stop to an arrest by handcuffing the suspect and holding him at gunpoint. But because the officers entered the house without any information as to who might be inside, that entry could not be justified as a protective sweep under Maryland v. Buie (1990) 494 U.S. 325.