Detaining individuals at the scene of a search.
The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.
According to the U.S. Supreme Court, "physical entry of the home is the chief evil against which the wording of the Fourth Amendment is directed." (1) A basic principle of Fourth Amendment law is the requirement that before searching a residence, police officers are required to obtain a valid search warrant prior to entry into the home. (2) Searches are considered unreasonable unless conducted under the authority of a search warrant or they fall under a valid exception to the warrant requirement. (3) Once a search warrant for a residence is issued, however, officers are permitted to enter the residence and conduct a search of the location described in the warrant for the items listed in that warrant. In addition to conducting the search, officers often encounter people. Generally, these people are neither named nor identified in the search warrant itself. At this point, an important question arises--what legal basis, if any, permits police officers to exercise control over people they encounter during the execution of a warrant? This article addresses the authority of police officers to detain people present at the scene of a search warrant and what degree of force may be used during the detention.
THE AUTHORITY TO DETAIN UNDER A SEARCH WARRANT
Michigan v. Summers (4)
As Detroit police officers were about to execute a search warrant for drugs, they observed an individual, later identified as George Summers, leave the front door of the residence specified in the warrant. (5) Police officers approached Summers and requested that he open the door to the dwelling. Summers told the officers that he had left his keys in the residence and then used an intercom to summon someone inside to come to the door. An individual came to the door but refused entry to officers after they identified themselves. The officers forced the door open and brought Summers inside the premises where he was detained for the duration of the search. The officers then located and detained all other individuals inside the residence and conducted their search. After finding narcotics in the basement and learning that Summers owned the house, the police officers arrested Summers. A search of Summers incident to his arrest located 8.5 grams of heroin inside his coat pocket.
Following the government's decision to charge him with drug possession, Summers moved to suppress the heroin found on his person. (6) Summers argued that the police officers had no authority to detain (or seize) him outside his residence before they executed the search warrant and that the heroin found on his person was the fruit of this unlawful seizure. The Michigan Supreme Court affirmed the lower court's ruling, agreeing the evidence should be suppressed as the initial seizure of Summers violated the Fourth Amendment. (7) The government then appealed the decision to the U.S. Supreme Court.
The Supreme Court disagreed with the previous rulings, holding that even though the officers did not have probable cause to arrest Summers initially, the detention of Summers was reasonable nevertheless. In so holding, the Court noted that some seizures covered by the Fourth Amendment "constitute such limited intrusions on the personal security of those detained" that they do not require probable cause but only an "articulable basis for suspecting criminal activity." (8) As for the basis for suspecting criminal activity, the Court turned to the significance of the existence of a search warrant. The issuance of the search warrant indicated that a "neutral and detached magistrate had found probable cause to believe that the law was being violated in that house and had authorized a substantial invasion of the privacy of the persons who resided there." (9) The Court noted that the detention of one of the residents was "less intrusive than the search itself" and then set forth three government interests that supported the need for a detention of the occupants at the scene of a search warrant: 1) "the legitimate law enforcement interest in preventing flight in the event that incriminating evidence is found"; 2) "minimizing the risk of harm to the officers"; and 3) "the orderly completion of the search." (10) In balancing the interests of law enforcement executing a search warrant against the limited intrusion into personal freedom, the Court found the balance favored the government. The Court also noted that the "connection of an occupant to that home gives the police officer an easily identifiable and certain basis for determining that suspicion of criminal activity justifies a detention of that occupant." (11) The Court upheld the authority of the police officers to detain Summers prior to and during the search of his premises while announcing the following rule:
A warrant to search for contraband found on probable cause implicitly carries with it the limited authority to detain the occupants of the premises while a proper search is conducted. (12)
Under the facts of the Summers case, the police officers were permitted to detain Summers because he was observed departing the premises for which the officers possessed a valid warrant to search for drugs. Because the detention was reasonable under the Fourth Amendment, the later arrest and search of Summers based upon probable cause was permissible, and the narcotics found on his person were not found in violation of the Fourth Amendment. (13)
Muehler v. Mena (14)
While investigating a gang-related drive-by shooting, police officers developed information giving them reason to believe that an involved gang member lived at 1363 Patricia Avenue. Officers also believed that the suspect was armed and dangerous because of his participation in the recent shooting. The officers obtained a search warrant for the residence, seeking such items as guns and evidence of gang membership. The search warrant was executed by police officers and special weapons and tactics (SWAT) team members. After making entry, officers located four people inside the residence, including Iris Mena, who was found asleep in her bed. Officers handcuffed Mena and three other individuals found on the property and removed them to a converted garage where they were allowed to move around but were forced to remain handcuffed. (15) Other officers then conducted a search of the premises that resulted in the discovery of a gun, ammunition, and other evidence of gang activity. Mena was released by the officers before they left the area. Mena brought a civil lawsuit against the officers under Title 42, U.S. Code, Section 1983 (16) alleging that her detention by police officers at the scene of the search was unreasonable both in time and manner. The federal Court of Appeals for the Ninth Circuit affirmed a jury verdict in favor of Mena, noting that it was unreasonable to keep Mena handcuffed in the converted garage and that Mena should have been released as soon as officers determined that she posed no immediate threat. (17) The government appealed this case to the U.S. Supreme Court.
The Supreme Court initially noted that the detention of Mena was permissible under the authority granted to police officers as set forth in the Summers case. In this regard, the Court noted that "an officer's authority to detain incident to a search is categorical" and is not dependent on the "quantum of proof justifying detention or the extent of the intrusion to be imposed by the seizure." (18) The Court then held that the detention of Mena for the duration of the search was reasonable "because a warrant existed to search 1363 Patricia Avenue and [Mena] was an occupant of that address at the time of the search." (19)
The Court then addressed the manner in which Mena was detained during the search--the use of handcuffs on Mena and noted that "[i]nherent in Summers' authorization to detain an occupant of the place to be searched is the authority to use reasonable force to effectuate the detention." (20) While the use of properly applied handcuffs for the duration of the search was an additional intrusion beyond the detention permitted in Summers, their use was reasonable under the circumstances of this case due to the nature of "the safety risk inherent in executing a search warrant for weapons" and made all the more reasonable because of the need to detain multiple occupants. (21) The Supreme Court found in favor of the police officers and upheld the authority of the officers to detain Mena in handcuffs during the execution of the search warrant. (22)
REQUIREMENTS FOR DETENTION INCIDENT TO A SEARCH WARRANT
A clearly stated rule can be deduced from the two U.S. Supreme Court cases discussed so far. However, although police officers executing a valid search warrant (23) for contraband have the authority to use reasonable force to detain occupants of the premises, (24) some aspects of this rule remain open to interpretation.
When the Supreme Court announced the rule in the Summers case, it noted "[t]he connection of an occupant to that home gives a police officer an easily identifiable and certain basis for determining that suspicion of criminal activity justifies a detention of that occupant." (25) According to the Court, this authority to detain is "categorical" and does not require police officers to evaluate their authority on a case-by-case basis. (26) This is consistent with the Supreme Court's recognition of the interest of police officers to "routinely exercise unquestioned command" of the scene of a search warrant. (27) The presence of the search warrant itself justifies the detention of the occupants, and the occupants are easily identifiable by their connection to the location to be searched. There is no requirement that the officers possess any suspicion beyond the warrant itself to justify the detention. (28) Therefore, police officers, after valid entry under a search warrant, are permitted to locate and detain occupants present within the location of the search in situations where the officers are confronted with factors consistent with those in Summers and Mena. In this regard, it is important to determine the definition of the word occupan t. For example, several circuit courts of appeals have expressly recognized the difference between the terms occupant and resident. (29) The authority to detain incident to the search warrant does not depend upon a determination by police officers of whether the subject of the detention actually resides at the location described in the search warrant. Police officers did not determine that Summers owned the premises until after he had been detained by the police and before they executed the search warrant. (30) But, Summers, like Mena, was not alone inside the location of the search as the police officers detained several other occupants located inside the residence. The additional occupants themselves may be detained by police officers simply because they are occupants of the premises being searched.
Detaining Subjects Approaching and Leaving the Scene
Other situations may arise that are not as obvious as detaining a person present at the scene of the search or one who has just left the scene. Since Summers, lower courts have interpreted this detention authority to extend even beyond the most obvious cases when law enforcement interests outweigh an individual's personal freedom. For example, several courts have determined that police officers may detain subjects approaching the location where police officers are executing or about to execute a search warrant. (31) Police officers have been permitted to detain individuals who have left the location of a search and are a short distance away from the scene (32) and those neither entering nor leaving the location to be searched but are present in the backyard. (33) One federal circuit court of appeals upheld the detention of a subject leaving the scene of the search when police officers did not have physical possession of the warrant but were aware that the warrant had been issued and was being brought to the scene. (34)
A common thread running through these cases is the court's focus that those detained are "easily identifiable" to police officers by their connection to the location to be searched. In summary, courts have recognized the authority of police officers when executing a search warrant for contraband to detain 1) those present at the location of the search; 2) those leaving the scene of the search at or immediately before the execution of the warrant; and 3) those who arrive at the scene of a search. This ensures that the risk of flight is minimized, the safety of the officers is protected, and the search may be completed in an orderly fashion.
USE OF REASONABLE FORCE
A likely scenario emerging during the execution of a search warrant is the need to detain individuals and place them in handcuffs. The court cases dealing with issues arising out of the execution of search warrants frequently involve defendants alleging that a police officer violated their Fourth Amendment rights upon 1) the initial detention and 2) in the amount of force used by the officers to make this detention. While Summers clearly addressed the scope of the authority to detain individuals, the level of force that may be used to effect this seizure, including the use of handcuffs, presents a separate and sometimes more difficult question. The determination of what constitutes reasonable force under the varying circumstances presented during the execution of search warrants requires careful consideration.
The Mena case is particularly instructive with regard to the level of force that police officers may use in detaining a person incident to the execution of a search warrant. In Mena, the Supreme Court specifically recognized what was implied in Summers: police officers have the authority to use reasonable force to detain the occupant present at the location of a search. (35) In Summers, the Supreme Court noted that the protections of the Fourth Amendment are "meaningful only when it is assured that at some point, the conduct of those charged with enforcing the laws can be subjected to the more detached, neutral scrutiny of a judge." (36) While it may appear minimally intrusive to law enforcement to detain and possibly handcuff an individual, to the individual detained, intrusions on personal freedom are quite meaningful and thus may be subjected to later judicial scrutiny. (37) Under the reasonableness standard, a court must look to determine whether the conduct of the police officer was objectively reasonable in light of the facts confronting the officer at the moment force is used. (38) If it is determined that the conduct of an officer was objectively reasonable, then the requirements of the Fourth Amendment are satisfied.
In the Mena case, the police officers executing the search warrant "entered [Mena's] bedroom and placed her in handcuffs at gunpoint." (39) In analyzing the level of force used to detain Mena, the Supreme Court noted that the use of properly applied handcuffs was reasonable under the situation. (40) The Court noted that the police officers in this case were not involved in an "ordinary search" but one that involved a warrant authorizing the search for weapons at the residence of a wanted gang member. (41) The use of handcuffs to detain Mena and the other occupants minimized the risk of harm to the officers and the occupants. (42) Additionally, the use of handcuffs for the duration of the 2-to 3-hour search also was found to be reasonable by the Supreme Court, although the Court noted that duration of detention could affect the reasonableness of the seizure. (43)
It is significant to note that the Supreme Court did not require the officers to articulate an individualized factual basis to justify the use of handcuffs on Mena. The police officers were permitted to handcuff Mena because she was present at the scene of a search for weapons, and they were not required to make a determination independent of the warrant as to whether Mena actually posed a safety risk to the officers. The Supreme Court indicated that sufficient justification arose from the nature of the search warrant itself, as authorized by a judicial determination on probable cause, that items listed in the warrant to be seized included weapons at the location of the home of a suspected gang member, a situation labeled "inherently dangerous." (44)
Of significance, the Supreme Court did not authorize the use of handcuffs on occupants during the execution of every search warrant. To reinforce this point, Justice Kennedy, in his concurring opinion, also addressed the issue of handcuffing occupants during the execution of search warrants "to help ensure that police handcuffing during searches becomes neither routine nor unduly prolonged." (45) Justice Kennedy believed that it is important to consider the expected or actual duration of the search when determining whether continued use was objectively reasonable. In addition, he provided three examples where he believed that handcuffs, even if initially applied properly, should be removed: 1) if the search extends to the point where the handcuffs can cause real pain or serious discomfort; 2) if it became readily apparent to any objectively reasonable officer that removing the handcuffs would not compromise the officer's safety; or 3) if it risked interference or substantial delay in the execution of the search. (46) Justice Kennedy believed that the continued detention of Iris Mena in handcuffs for the duration of the search was reasonable because the "detainees outnumber[ed] those supervising them, and this situation could not be remedied without diverting officers" from the search. (47)
While the use of handcuffs to detain individuals in the execution of every warrant is not authorized, the Supreme Court has found that the execution of two types of searches raises special concerns for police officers by the very nature of the search warrant itself. The Summers case involved a search of a residence for narcotics. In this context, the Supreme Court noted "the execution of a warrant to search for narcotics is the kind of transaction that may give rise to sudden violence or frantic efforts to conceal or destroy evidence." (48) The Mena case involved a search for weapons at the home of a suspected gang member, which the Supreme Court characterized as "inherently dangerous." (49) In both of these cases, the Supreme Court noted that there was no indication of the existence of any special danger to police officers from their observations at the scene. Yet, the Court upheld the detention in Summers and the detention and handcuffing in Mena. The justification for this action arises from the nature of the particular search warrants alone and suggests that the government interests are at their maximum in at least these two situations. (50)
Lower federal courts have generally been deferential to the use of handcuffs by police officers executing warrants for narcotics or weapons without any individualized suspicion directed at the person so detained. For example, police officers executing a search warrant for drugs in a dormitory room knocked on the door and were admitted by one of the occupants. As the occupant opened the door, he observed the police officers' weapons pointed at him, and then "armed officers entered the room, loudly ordered [the occupants] to get on the floor, and handcuffed them." (51) One of the occupants claimed that this seizure violated his Fourth Amendment rights, but the court ruled that the use of the handcuffs was "an appropriate measure incident to the search, [and] there was no evidence that any excessive force was used during the detention" and, thus not unconstitutional. (52) Police officers approaching a residence to execute a drug search warrant observed five males in the yard. The officers "drew their weapons, ordered all of the men to lie face down on the ground, and handcuffed them." In addressing the lawfulness of the detention of one of the occupants, the circuit court noted that "the police were not unreasonable in restraining persons found on the property during the search in order to protect the officers' safety." (53)
While the use of handcuffs to detain individuals at the scene of a drug search warrant is generally found to be reasonable, (54) it is possible the conduct of police officers after applying the handcuffs can cause a violation of the Fourth Amendment. For example, police officers used handcuffs to detain an individual who approached the scene of a drug search warrant but was then placed inside an unventilated police car in 90-degree heat for 3 hours. (55) The court concluded that the use of handcuffs was permissible, but the "unnecessary detention in extreme temperatures," especially because there were other "effective alternative ways" of detaining the individual, violated the Fourth Amendment. (56)
NATURE OF THE SEARCH WARRANT
Outside the context of executing a search warrant for drugs or weapons, the use of handcuffs to detain occupants results in more exacting judicial scrutiny. While IRS agents were executing a warrant to search a building for evidence of income tax violations, they were confronted by Gayle Bybee, an individual who lived in the building, who loudly and repeatedly requested to see the warrant. The agents handcuffed this individual for the duration of the search. (57) In ruling on the lawfulness of the use of handcuffs by the agents to detain Bybee, the federal Circuit Court of Appeals for the Ninth Circuit noted that "detaining a person in handcuffs during the execution of a warrant to search for evidence is permissible but only when justified under the totality of the circumstances." (58) In this regard, the court noted that the officers had no reason to believe that the occupants were dangerous, (59) and the warrant sought evidence for nonviolent crimes. Based upon the circumstances confronting the IRS agents, the use of handcuffs to detain Gayle Bybee was a violation of her Fourth Amendment rights. (60)
The Summers case specifically addressed the authority of police officers to detain occupants incident to a search warrant authorizing a search for contraband and "d[id] not decide whether the same result would be justified if the search warrant merely authorized a search for evidence." (61) The Court did not explain this limitation but referred to a case it had decided previously in which it upheld the use of a search warrant to obtain evidence that was in the possession of a third party not involved in the criminal activity. (62) Presumably, the likely reason for this apparent limitation is based upon the connection between the occupant of the residence and the crime itself. For example, when a court issues a search warrant for contraband within a residence, there has generally been a judicial determination that the police have probable cause to believe that an occupant of the home is committing a crime or, at least, there is a connection between the occupant and the crime. Thus, the interests of the government supporting the detention of occupants as set forth in the discussion of the Summers case would permit a detention. However, in cases where a search warrant is issued that seeks evidence only, especially evidence that may be located at the residence of a person who is not connected to the crime or may not even be aware of the crime, automatic detention under the Summers rule may not be justified. (63)
However, circumstances in a given case may justify more intrusive approaches depending on the circumstances even when serving a warrant that does not seek contraband. For instance, the federal Circuit Court of Appeals for the Tenth Circuit ruled in a case involving a warrant for the seizure of stolen property (64) that detention of persons encountered during the search was permissible as the definition of contraband was broad enough to cover stolen property. In another case, a warrant seeking evidence of tax evasion did not justify detention of the occupants. The court noted that the warrant sought evidence and not contraband, and it could "not assume that the Summers' general rule automatically applies." (65)
Police officers possessing a search warrant for contraband also may possess authority to conduct more than a search of the location described in the warrant. The U.S. Supreme Court has expressly recognized the compelling interests of law enforcement to maintain control of the scene of a search to allow for its safe and orderly completion. In recognition of these interests, the Supreme Court has determined that police officers serving a search warrant for contraband possess categorical authority to detain occupants present at the scene and use force reasonable and necessary to carry out the detention and maintain control over the location of the search. Presearch planning should take into account this authority, including allocating and tasking personnel, with the responsibility of maintaining control over those present at the search location.
(1) United States v. U.S. District Court, 407 U.S. 297 (1972).
(2) This article does not address exceptions to the Fourth Amendment that may permit the entry into and search of a residence without a warrant.
(3) Payton v. New York, 445 U.S. 573 (1980).
(4) Michigan v. Summers, 452 U.S. 692 (1981).
(5) Id. at 692.
(6) Summers was not charged for the narcotics found in his home. See note 7.
(7) People v. Summers, 286 N.W.2d 226 (1979).
(8) Id. at 699-700.
(9) Id. at 701.
(10) Id. at 702.
(11) Id. at 703-704.
(12) Id at 705.
(14) Muehler v. Mena, 544 U.S. 93, 95 (2005).
(15) Id. at 93.
(16) 18 U.S.C. [section]1983 (This statute allows citizens to bring allegations of violations of their constitutional rights by police officers into federal court.).
(17) Mena v. Simi Valley, 332 F.3d 1255 (9th Cir. 2003).
(18) Muehler v. Mena, 544 U.S. 93, 98 (2005), quoting Michigan v. Summers, 452 U.S. 692, at 705 n. 19.
(19) Id. at 98.
(20) Id. at 98-99.
(22) But, see Mena v. City of Simi Valley, 156 Fed. Appx. 24 (9th Cir. 2005) (On remand from the Supreme Court, the Ninth Circuit determined that the police officers detained Mena in handcuffs after the search was completed in violation of the Fourth Amendment.).
(23) A valid warrant describes a warrant that is facially valid, issued on probable cause, supported by oath or affirmation, and contains a particular description of the location to be searched and the items to be seized.
(24) Wayne LaFave, Search and Seizure, [section]4.9.
(25) Michigan v. Summers, 452 U.S. 692, 703-704.
(26) Id. at 705, n.19.
(27) Id. at 703.
(28) Compare with Terry v. Ohio 392 U.S. 1 (1968) which requires police officers to articulate a reasonable suspicion to justify a limited detention.
(29) United Stales v. Cavazos, 288 F.3d 706 (5th Cir. 2002); United Stales v. Fountain, 2 F.3d 656 (6th Cir. 1993) cert. denied 114 S. Ct. 608 (1993); United States v. Pace, 898 F.2d 1218 (7th Cir. 1990).
(30) Id. at 693.
(31) See Burchett v. Kiefer, 310 F.3d 937 (6th Cir. 2002) (detention of person approaching property being searched, pauses and then flees); United States v. Bohannon, 225 F.3d 615 (6th Cir. 2000) (detention of subjects driving up to the scene of a search); Baker v. Monroe Township, 50 F.3d 1186 (3rd Cir. 1995) (detention of invited dinner guests arriving as the search commenced).
(32) United States v. Briley, 319 F.3d 360 (8th Cir. 2003); United States v. Small-wood, 86 F.3d 27 (2nd Cir. 1996); United States v. Cochran, 939 F.2d 337 (6th Cir. 1991); But, see United States v. Reinholz, 245 F.3d 765 (8th Cir. 2001) (Detention not authorized when defendant was at work at least 25 miles away from residence at the time of the search.); United States v. Edwards, 103 F.3d 90 (10th Cir. 1996) (Summers does not apply where defendant was stopped 3 blocks from the search.).
(33) United States v. Vite-Esponoza, 342 F.3d 462 (6th Cir. 2002).
(34) United States v. Ritchie, 35 F.3d 1477 (10th Cir. 1994).
(35) Muehler v. Mena, 544 U.S. 93, 98-99 (2005).
(36) Michigan v. Summers, 452 U.S. 692, 700 (1981).
(37) Graham v. Connor, 490 U.S. 386 (1989).
(38) Id. at 394-395.
(39) Muehler v. Mena, 544 U.S. 93, 96 (2005).
(40) Id. at 99.
(41) Id. at 100.
(43) Id. See n. 14.
(45) Id. at 102 (Kennedy concurring).
(46) Id. at 103 (Kennedy concurring).
(48) Michigan v. Summers, 452 U.S. 652, 703 (1981).
(49) Muehler v. Mena, 544 U.S. 93, 100 (2005).
(50) 544 U.S. at 100, 452 U.S. at 702-703.
(51) Mazuz v. Maryland, 442 F.3d 217, 222 (4th Cir. 2006). It is interesting to note that the police officers entered the wrong room, but the court of appeals determined that this mistake was reasonable, and, thus, the entry and detention of the occupants was constitutional.
(52) Id. at 231.
(53) United States v. Thompson, 91 F.3d 145 (6th Cir. 1996).
(54) See Hinson v. West, 2006 WL 1526895 (M.D. Ala, 2006) (Use of handcuffs on two infirm women for duration of search for drugs held unconstitutional.).
(55) Burchett v. Kiefer, 310 F.3d 937 (6th Cir. 2002).
(56) Id. at 945.
(57) Meredith v. Erath, 342 F.3d 1057 (9th Cir. 2003).
(58) Id. at 1063-1064.
(59) Police officers also should be aware that the use of force and handcuffs on children who may be present at the search scene raises additional concerns. The Supreme Court has not addressed the particular issue, but lower federal courts have clearly drawn a distinction between the amount of force that may be used on an adult and that which may be used on a child. See Tekle v. United States, 457 F.3d 1088 (9th Cir. 2006); Holland v. Harrington, 268 F.3d 1179 (10th Cir. 2001).
(60) Id. at 1064 (However, the officers were granted qualified on this point because this right was not clearly established at the time the officers used handcuffs to detain Bybee.).
(61) Michigan v. Summers, 452 U.S. 652, 705 n.20 (1981). But, see Dawson v. City of Seattle, 435 F.3d 1054 (9th Cir. 2006) (The authority to detain occupants incident to a search for evidence of violations of the Seattle Health Code under both Summers and Mena "apply to all searches upon probable cause not just to searches for contraband.").
(62) Zurcher v. Stanford Daily, 436 U.S. 547 (1978).
(63) See Denver Justice and Peace Committee, Inc. v. City of Golden, 405 F.3d 923 (10th Cir. 2005); Daniel v. Taylor, 808 F.2d 1401 (11th Cir. 1986) (Summers rule is not applicable "to a search for evidence, because the existence of mere evidence, as opposed to contraband, on the premises does not suggest that a crime is being committed on the premises.").
(64) United States v. Ritchie, 35 F.3d 1477 (10th Cir. 1994).
(65) Leveto v. Lapina, 258 F.3d 156, 170 n.6 (3rd Cir. 2001).
Law enforcement officers of other than federal jurisdiction who are interested in this article should consult their legal advisors. Some police procedures ruled permissible under federal constitutional law are of questionable legality under state law or are not permitted at all.
By CARL A. BENOIT, J.D.
|Printer friendly Cite/link Email Feedback|
|Title Annotation:||Legal Digest|
|Author:||Benoit, Carl A.|
|Publication:||The FBI Law Enforcement Bulletin|
|Date:||Dec 1, 2006|
|Previous Article:||Missing person.|
|Next Article:||The Bulletin Notes.|