Search and seizure is a procedure used by police officers to search a person/place for any relevance to the crime with suspicion. In the Bailey case, Michigan v. Summers had a strong bearing on the case to show that Bailey's detention was justifiable as both scenarios share a similar scenario. Both cases involved a police officer obtaining a search warrant to obtain evidence of contraband at a residence. Both also involved an individual within the premises of the area who had left the family unit. This is the difference found when George Summer, in Summer vs Michigan, encountered the police as Summer came down the steps. Summer was asked to assist them and possibly detained on the premises to avoid contamination of evidence. It was then searched after the officer found cocaine in the apartment and found drugs in Summer's possession. In the case, Bailey left before the search warrant was executed. So the search did not begin and the search and seizure was questionable as Bailey posed no suspect or threat to the search. In the end, Bailey was illegally