After finding narcotics in the basement and ascertaining that Summers owned the house, the police arrested him, searched his person, and found in his coat pocket an envelope containing 8.5 grams (0.30 oz) of heroin.

He moved to suppress the heroin as the product of an illegal search in violation of the Fourth Amendment and the trial judge granted the motion and quashed the information.

Justice Stevens, writing for the majority, noted that the detention did amount to a 'seizure' within the meaning of the Fourth Amendment and assumed that the seizure was not supported by probable cause.

However, the majority likened this case to its jurisprudence on street frisks, in Terry v. Ohio, and border searches, in United States v. Brignoni-Ponce, and explained that an exception to the general requirement of probable cause might be made based on the "character of the official intrusion and its justification."

[2][3] One scholar has made the case that the Summers rule has been "extended well beyond what the Court's initial rationale should reasonably allow" and, as a result, has "put at risk the very liberty interests that it was designed to protect.