WILNER, J.
On an agreed statement of facts, petitioner, Steven Cotton, was convicted in the Circuit Court for Caroline County of possession of marijuana, for which, as a repeat offender, he was sentenced to two years in prison. That judgment was affirmed by the Court of Special Appeals. The marijuana that formed the basis of his conviction was taken from him by Caroline County Detective James Henning when Cotton, after receiving Miranda warnings, admitted to Henning that he had the drug in his possession. Cotton’s only complaint is that, at the time of this encounter with Detective Henning, he was under an unlawful arrest and that both his admission and the ensuing search, as the fruit of that unlawful arrest, were inadmissible in evidence. We find no merit in that argument and shall therefore affirm the judgment of the Court of Special Appeals.
BACKGROUND
An extensive four-year investigation by the Caroline County Sheriff’s Office established that Don Antonio Jones, his grandfather, Calvin Edgar Bolden, and his mother, Calvileen Bolden, were operating an open-air drug market from and around their home at 329 Brooklyn Avenue, in Federalsburg. The investigation revealed that (1) significant quantities of drugs were brought into the house by Jones, (2) the drugs were being sold not only in the house but around it as well, from the front porch and within what we would regard as the curtilage, (3) many of the individuals observed in the trafficking, including Jones and Calvin Bolden, had extensive drug-crime records, and some of them had a record of violent crimes, and (4) Jones, in particular, (i) associated with individuals who had extensive backgrounds in assaults, attempted [252]*252murders, and handgun violations, (ii) had established an elaborate counter-surveillance network around the vicinity of the house, and (iii) had threatened that “a member of the police department is going to get ‘shot’ if the police do not back off with patrols in the Brooklyn, Federalsburg area.”
Based on this and a great deal more, all carefully set forth in a 68-page verified application, a District Court judge found probable cause to believe that violations of the controlled dangerous substance laws were occurring “in and upon” 829 Brooklyn Avenue — not just the residence but outbuildings and motor vehicles on the property as well. Upon that finding, the court issued a warrant that authorized the police to enter and search, without the need for a knock or announcement of police presence, the residence and any outbuildings and motor vehicles located “on said property.” The warrant empowered the police to search the persons and clothing of Jones, Calvileen and Calvin Bolden, and “any other persons found in or upon said premises who may be participating in violations of [those statutes] and who may be concealing evidence, paraphernalia, and Controlled Dangerous Substances,” to seize all evidence “found in or upon said premises,” and to arrest “all persons found in or upon said premises ... who are participating in violations of [those statutes].”
Although only three persons were named in the warrant— Jones and the two Boldens — the affidavit established that several other people with a history of criminal and violent conduct were involved, and the warrant clearly anticipated that some of them may be on or about the property when the warrant was executed. Hence, the authorization to enter the house without knocking or announcing the police presence and to arrest “all persons” found in or upon the premises who may be participating in violations of the drug laws.1
[253]*253Given that they were dealing with an open-air drug market, that an unknown number of people might be present when the warrant was executed, and that some of those people might be violent and likely to resist or flee, the police understandably arrived in force. Some twenty to twenty-five officers participated.2 When the police arrived, they found at least four people, including Jones and Cotton, in the front yard near the porch — an area in which much of the drug activity described in the application for the warrant had taken place. Jones immediately fled, requiring two officers to pursue and ultimately capture him. The other people were handcuffed and detained under guard. There was no evidence that they were held at gunpoint. Cotton was allowed to sit on a bucket or log. Detective Henning explained:
“That is standard procedure based on being in an open air drug market and doing this type of no knock warrant, we had — everyone is detained, placed on the ground for our safety and detained at that position where they’re at while the rest of the place is secured, and securing a residence doesn’t just take two minutes, three minutes, it probably would take about ten to fifteen minutes to make sure that all the rooms, attics, crawl spaces, everything is secured before anyone does anything else.”
The detective added that it was not just a matter of securing the house itself:
“Basically we set up a perimeter as they are securing the house, we’re setting up a perimeter, making sure no one doubles back around on us or anything to that effect, so yes, after I would say [ten to fifteen] minutes. However long it [254]*254took to get the house totally secured is when I start making my rounds to people.”
The detective explained that, once the house was secured, which took about ten to fifteen minutes, he began to interview the people who had previously been detained. He began with Steven Aldredge, who was on or near the porch with Cotton and Jones when the police arrived. Henning had what he said was a “brief conversation” with Aldredge. As Henning was talking to him, a police dog alerted to Aldredge’s car. Henning requested and obtained permission to search both Al-dredge and the car, and, when no contraband was found, Aldredge was promptly released. Henning then turned immediately to Cotton. He testified:
“I approached the Defendant, I told him what was going on, a search and seizure warrant was being executed. I immediately advised him of his Miranda rights, I asked him if he had anything on him, he said, ‘All I’ve got is a bag of weed, that’s all I got.’ At that point I said okay, that’s fine. I got all the pertinent information, he was subsequently searched behind the residence further, to determine if he had anything else and he just remained in the scene until we were able to get a transport unit there.”
Henning said that he asked the question, after giving the Miranda warnings, to determine whether Cotton had any weapons or needles that might jeopardize Henning’s safety, and that he patted Cotton down after Cotton’s admission that he was in possession of marijuana. Henning regarded the pat-down as a Terry v. Ohio frisk. The marijuana that was found on Cotton is what led to his conviction for possession of the substance.
Cotton looks on this procedure as transgressing his Constitutional rights. He urges that so far as the police were concerned, he was a mere bystander who happened to be on the scene when they came to execute the warrant for the Bolden-Jones home, that they had no probable cause to believe that he had committed any crime or had any contraband in his possession, and that they therefore had no lawful [255]*255authority to detain him. The detention, he avers, constituted an unlawful arrest, and the interrogation and search that followed it were, as a result, equally unlawful. The de facto arrest, he says, arose from the fact that he was detained for upwards of twenty minutes, during which time he was handcuffed, kept under guard, and given the Miranda warnings.
DISCUSSION
The Fourth Amendment does not prohibit all searches and seizures, but only those that are unreasonable. United States v. Sharpe, 470 U.S. 675, 682, 105 S.Ct. 1568, 1573, 84 L.Ed.2d 605, 613 (1985); Maryland v. Buie, 494 U.S. 325, 331, 110 S.Ct. 1093, 1096, 108 L.Ed.2d 276, 284 (1990). The starting point for a proper analysis of reasonableness is Michigan v. Summers, 452 U.S. 692, 101 S.Ct. 2587, 69 L.Ed.2d 340 (1981).
As the police were about to execute a warrant to search a house for narcotics, they observed Summers coming down the front steps. The police detained him while they searched the house and, after finding narcotics in the basement and learning that Summers owned the house, they arrested and searched him, finding heroin in his coat pocket. Clearly at that point they had probable cause to make the arrest, but the question before the Court — -just like the question before us in this case — was the legality of the initial detention: was it an arrest that required probable cause or was it an investigative seizure that could be justified on less than probable cause?
Examining earlier cases, in particular Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968) and its extensive progeny, the Court confirmed that “some seizures admittedly covered by the Fourth Amendment constitute such limited intrusions on the personal security of those detained and are justified by such substantial law enforcement interests that they may be made on less than probable cause, so long as the police have an articulable basis for suspecting criminal activity” and that “the exception for limited intrusions that may be justified by special law enforcement interests is not confined [256]*256to the momentary, on-the-street detention accompanied by a frisk for weapons involved in Terry and Adams [v. Williams, 407 U.S. 143, 92 S.Ct. 1921, 32 L.Ed.2d 612 (1972)].”
Of particular importance in Summers was the fact that the police had obtained a warrant to search the house. The Court observed that, although the detention of Summers admittedly constituted a significant restraint on his liberty, justification for that detention also had to consider the law enforcement interest, and, in that regard, it made and emphasized the point seemingly lost on both Cotton and the Dissent in this case:
“Most obvious is the legitimate law enforcement interest in preventing flight in the event that incriminating evidence is found. Less obvious, but sometimes of greater importance, is the interest in minimizing the risk of harm to the officers. Although no special danger to the police is suggested by the evidence in this record, 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. The risk of harm to both the police and the occupants is minimized if the officers routinely exercise unquestioned command of the situation.”
Michigan v. Summers, supra, 452 U.S. at 702-03, 101 S.Ct. at 2594, 69 L.Ed.2d at 349-50. (Emphasis added).
Although there were a number of people found in the home and detained by the police, the Summers case involved only Summers himself, who was a resident. In analyzing the issue before it and ultimately holding that a limited detention of Summers was permissible, the Court sometimes used the word “resident” and sometimes the word “occupant” to describe who may properly be detained, and that has engendered considerable debate over whether anyone other than an actual resident of the home may be detained in the absence of independent probable cause or articulable suspicion. Most recently, the Supreme Court has characterized Summers as dealing with ‘occupants.’ ” See Mushler v. Mena, 544 U.S. -, 125 S.Ct. 1465, 161 L.Ed.2d 299 (2005).
[257]*257In Stanford v. State, 353 Md. 527, 727 A.2d 938 (1999), we noted that three lines of cases had developed: those flatly holding that only actual residents of the home may be detained while the search proceeds; those adopting that view generally but allowing the detention of non-residents if the police “can point to reasonably articulable facts that associate the visitor with the residence or the criminal activity being investigated in the search warrant”; and those that “broadly define ‘occupants’ to include those visiting the residence to be searched.” Id. at 535-38, 727 A.2d at 942-44. We pointed out that the cases in that third category tend to resolve the validity of the detention of visitors by “comparing the nature of the police intrusion with any valid law enforcement interests in the detention.” Id. at 537-38, 727 A.2d at 943-44. Because we concluded that the detention of Mr. Stanford was unlawful under any of those approaches, we did not need to decide which of them was the most appropriate.
Since Stanford, it appears that at least three Federal appellate courts and one State Supreme Court have adopted approaches broader than the first and closer to the second or third. See United States v. Photogrammetric Data Services, Inc., 259 F.3d 229 (4th Cir.2001), cert. denied, 535 U.S. 926, 122 S.Ct. 1295, 152 L.Ed.2d 208 (2002), abrogated on other grounds by Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004) (detention of employees while business office searched pursuant to warrant permissible under Summers); Ganwich v. Knapp, 319 F.3d 1115 (9th Cir. 2003) (same); United States v. Cavazos, 288 F.3d 706 (5th Cir.2002), cert. denied, 537 U.S. 910, 123 S.Ct. 253, 154 L.Ed.2d 189 (2002); State v. Vorburger, 255 Wis.2d 537, 648 N.W.2d 829 (2002).
Subject to further instruction from the Supreme Court, we think that the second two approaches, or some synthesis of them, are more consistent with recent jurisprudence and represent a more reasoned and practical solution, in that they focus on the actual circumstances surrounding the issuance and execution of the warrant. Although Summers itself dealt only with a resident, the validity of the detention rested on [258]*258precepts derived from Terry and its progeny. If, to minimize the risk of harm to both police and occupants, the police are authorized to “routinely exercise unquestioned command of the situation,” persons, other than just residents, who are found in or about the premises are likely to be temporarily detained as well, at least until the police can find out who they are and whether they are involved in any of the illegal activities taking place at the home.
That authority was at least implicitly confirmed in Maryland v. Buie, supra, where, in executing an arrest warrant for Buie, police entered his home, immediately fanned out through the home looking not just for Buie but anyone else who might be there, and continued that sweep even after Buie had been located and arrested. Reversing a contrary decision by this Court, the Supreme Court concluded that the officers had an interest “in taking steps to assure themselves that the house in which a suspect is being, or has just been, arrested is not harboring other persons who are dangerous and who could unexpectedly launch an attack.” Maryland v. Buie, supra, 494 U.S. at 333, 110 S.Ct. at 1098, 108 L.Ed.2d at 285. (Emphasis added). The Court continued that “the arresting officers are permitted in such circumstances to take reasonable steps to ensure their safety after, and while making the arrest” and that “[t]hat interest is sufficient to outweigh the intrusion such procedures may entail.” Id. at 334, 110 S.Ct. at 1098, 108 L.Ed.2d at 286.
It follows, from Summers and Buie, that, in executing a warrant such as that issued here, for a premises known to be an open-air drug market where the police are likely to encounter people who may well be dangerous, they are entitled, for their own safety and that of other persons, to take command of the situation and, except for persons who clearly are unconnected with any criminal activity and who clearly present no potential danger, essentially immobilize everyone until, acting with reasonable expedition, they know what they are confronting. It really cannot be otherwise. The police do not know who may be at the scene when they arrive. The people [259]*259they find there, in or on the property to be searched, are not wearing identifying labels — supplier, customer, processor, bodyguard, innocent bystander. It would be decidedly unreasonable to expect the police simply to give a friendly greeting to the folks there and proceed to search the house without another thought as to who those people are or what they may do. Indeed, the Supreme Court has specifically warned against the very kind of “unrealistic second-guessing” of police officers that Cotton and the Dissent insist be done in assessing investigative detentions. See United States v. Sharpe, supra, 470 U.S. at 686, 105 S.Ct. at 1575, 84 L.Ed.2d at 616.
The question then becomes how long that detention may last. That answer was supplied in Sharpe, which involved the stop of a vehicle and the detention of its driver, and more recently in Muehler v. Mena, supra, 544 U.S. at -, 125 S.Ct. at-, 161 L.Ed.2d at-. In Sharpe, the police had some reasonable suspicion that Sharpe and Savage, driving different vehicles in tandem, were transporting marijuana. Sharpe was stopped first while another officer pursued and eventually stopped Savage. Savage was detained until the first officer arrived — about fifteen minutes later — whereupon his truck was searched and marijuana found in it. The issue before the Court was not the validity of the initial detention but rather its length. The Court concluded:
“In assessing whether a detention is too long in duration to be justified as an investigative stop, we consider it appropriate to examine whether the police diligently pursued a means of investigation that was likely to confirm or dispel their suspicions quickly, during which time it was necessary to detain the defendant.... A court making this assessment should take care to consider whether the police are acting in a swiftly developing situation, and in such cases the court should not indulge in unrealistic second-guessing .... A creative judge engaged in post hoc evaluation of police conduct can almost always imagine some alternative means by which the objectives of the police might have been accomplished. But ‘[t]he fact that the protection of the public might, in the abstract, have been accomplished by [260]*260“less intrusive” means does not, itself, render the search unreasonable’.... The question is not simply whether some other alternative was available, but whether the police acted unreasonably in failing to recognize or pursue it.”
Id. at 686, 105 S.Ct. at 1575-76, 84 L.Ed.2d at 615-16. (Citations omitted and emphasis added).
In Muehler, the police, pursuant to a warrant, raided a house in which at least one member of a violent gang was thought to live. Ms. Mena, an occupant of the house, was found asleep in her bed. She was placed in handcuffs at gunpoint and, along with three other persons found in trailers behind the house, taken to a converted garage and detained under guard for two-to-three hours. When the search of the house was completed, she was released. She then sued two of the officers under 42 U.S.C. § 1983, complaining, among other things, that her detention in handcuffs violated her Fourth Amendment rights. Reversing a contrary decision by the U.S. Court of Appeals for the Ninth Circuit, the Supreme Court, relying largely on Summers, held that, even though the detention of Ms. Mena was more instrusive than that of Mr. Summers, “[t]he officers’ use of force in the form of handcuffs to effectuate Mena’s detention in the garage, as well as the detention of the three other occupants, was reasonable because the governmental interests outweigh the marginal intrusion.” Id. at , 125 S.Ct. at-, 161 L.Ed.2d at-. The Court held further that the fact that the detention lasted two-to-three hours was not, itself, unreasonable, if it did not last longer than the search of the house required.3
Cotton places some weight — the Dissent even more — on one aspect of Baker v. Monroe Township, 50 F.3d 1186 (3rd Cir.1995), a split decision, without taking account of everything that the Third Circuit court said and did. Baker is actually instructive. Like Muehler, it was a § 1983 action [261]*261stemming from the rough treatment of the Baker family during a search of the home of Mrs. Baker’s son, Clementh. At about 8:30 on a June evening, Mrs. Baker, along with two of her teenage daughters and a teenage son, were approaching the home to have dinner with Clementh just as police from three jurisdictions arrived to execute a “no knock” drug raid. Some of the officers ran past them into the house, but others pointed guns at them and ordered them to the ground.
Initially, the Bakers named in their complaint only one officer, Armstrong, and the municipality that employed him, but, after the court found that Armstrong had not been involved in any wrongful conduct and entered summary judgment against them, they sought to amend their complaint to add the names of the other officers, who actually committed the allegedly wrongful conduct, which the trial court denied on limitations grounds. The principal issue on appeal was the propriety of the summary judgment in favor of Armstrong.4
Armstrong, one of the first officers to arrive, did order the Bakers to “get down” as he rushed into the house. The appellate court found no Fourth Amendment violation in that order. It observed that Armstrong, who was executing a “no knock” warrant, did not know who they were or whether they were entering or leaving the house but, because they were at or near the porch and he therefore suspected that they had some relationship to the house he had a warrant to search, he considered it necessary to get them on the ground to protect them from stray gunshots. Armstrong added that the presence of citizens standing in the middle of the raid could prevent the police from defending themselves, as they could not return fire in the middle of a crowd.
The court noted that “[t]he dangerousness of chaos is quite pronounced in a drug raid, where the occupants are likely to be armed, where the police are certainly armed, and the [262]*262nature of the suspected drug operation would involve a great deal of coming and going by drug customers” and, citing both Michigan v. Summers and Terry v. Ohio, concluded that “the need to ascertain the Bakers’ identity, the need to protect them from stray gunfire, and the need to clear the area of approach for the police to be able to operate efficiently all made it reasonable to get the Bakers down on the ground for a few crucial minutes.” Id. at 1191-92.
While the Bakers were outside, handcuffed and held at gunpoint by at least two officers, Mrs. Baker’s purse was snatched and emptied on to the street. After about ten minutes, Armstrong ordered that the Bakers be brought inside, where they were detained, still handcuffed and at gunpoint, for another fifteen minutes. Citing United States v. Sharpe, supra, the court found no Constitutional violation simply because of that extended detention: “We cannot say that a detention of fifteen minutes time to identify and release a fairly large group of people during a drug raid is unreasonable.” Baker, supra, 50 F.3d at 1192.
The problem lay in the fact that, during this entire 25-minute period, Armstrong was aware that the Bakers had been handcuffed and held at gunpoint and that Mrs. Baker’s purse had been seized and emptied. The court concluded that “adding up the use of guns and handcuffs and, indeed, the length of the detention, shows a very substantial invasion of the Bakers’ personal security,” that the police used those methods “without any reason to feel threatened by the Bakers, or to fear that the Bakers would escape,” and that “the appearances were those of a family paying a social visit, and while it may have been a visit to a wayward son, there is simply no evidence of anything that should have caused the officers to use the kind of force they [were] alleged to have used.” Id. at 1193. If Armstrong acquiesced in that behavior, he would have violated the Bakers’ Fourth Amendment rights.
Apart from whether the limited remand in Baker would be warranted under Muehler, the distinctions between Baker and this case are obvious. Cotton, an adult found standing next to [263]*263Jones at the porch where numerous drug transactions had been observed, could not have been mistaken for an innocent family member waiting for dinner to be served. Jones, who was known to associate with violent persons, fled and had to be chased. Not knowing Cotton, there was, indeed, reason for the police to feel threatened. Although Cotton was handcuffed until Detective Henning could speak with him, he was not held at gunpoint and he was not searched, as was Mrs. Baker, until after he admitted possessing marijuana. In short, the conduct that led the Baker court to conclude that summary judgment was inappropriate in the § 1983 action did not occur here. Indeed, the Baker court actually concluded that the kind of conduct that did occur here was not unlawful — not the initial detention, not the fifteen minute duration of it.
A case in point is United States v. Maddox, 388 F.3d 1356 (10th Cir.2004). Two Federal marshals and a deputy sheriff went to a mobile home to serve an arrest warrant on Rachel Page, a fugitive wanted for narcotics trafficking. When they arrived, they found Buhrle, the adult son of the owner of the home, in the driveway. They directed him to wait with the sheriff in the carport while the marshals went inside to arrest Page. While the marshals were inside, a truck carrying three people, including Maddox, appeared. The sheriff noticed Maddox reach under the seat but was unsure what he was doing. The sheriff had the three exit the truck and wait in the carport. Although Maddox began walking in circles in the carport, he made no attempt to escape. Eventually, three more people arrived and were held in the carport, although the sheriff then called for backup assistance. Before the backup arrived, the marshals escorted Page from the house but were required by local protocol to wait until a female officer arrived before escorting her from the area.
Upon arrival of the backup summoned by the sheriff, Maddox was separated from the others. When asked by a deputy whether he had any weapons or guns, Maddox replied that he had a concealed gun, some methamphetamine, and a scale. The deputy took possession of those items and arrested Mad[264]*264dox. This took place about a half hour after Maddox first arrived and was detained. Maddox, like Cotton here, moved to suppress the incriminating evidence on the ground that his detention and questioning were unlawful.
Relying largely on Maryland v. Buie, the Tenth Circuit Court of Appeals found no Fourth Amendment violation. Although Buie itself involved only a protective sweep of the house, the Maddox court concluded that the reasoning articulated by the Supreme Court applied as well to protective detentions immediately outside the home: “Because the ability to search for dangerous individuals provides little protection for officers unless it is accompanied by the ability to temporarily seize any dangerous individuals that are located during the search, we conclude that detaining potentially dangerous persons for the duration of the arrest qualifies as a ‘reasonable step [ ] to ensure the [officers’] safety.’ ” Maddox, supra, 388 F.3d at 1362, quoting in part from Buie.
The court noted that the sweep permitted in Buie was of the “arrest scene,” which, in the Maddox case, included the area immediately adjacent to the home. Like Cotton, Maddox, invoking Ybarra v. Illinois, 444 U.S. 85, 100 S.Ct. 338, 62 L.Ed.2d 238 (1979), urged that he was a mere bystander and that the sheriff should have simply sent him on his way. The court rejected that argument. In Ybarra, the police, in the course of executing an arrest warrant for the bartender of a tavern, proceeded to search all of the patrons of the tavern, which the Court held was impermissible — that “a person’s mere propinquity to others independently suspected of criminal activity does not, without more, give rise to probable cause to search that person.” Ybarra, supra, 444 U.S. at 91, 100 S.Ct. at 342, 62 L.Ed.2d at 245. (Emphasis added). The circumstances in the case before it led the Maddox court to conclude that there was more there — that Buie was the more relevant case — and it concluded that the sheriff had a reasonable articulable suspicion that Maddox posed a potential danger to the officers and that suspicion supported the temporary protective detention. See also United States v. Vite-Espino[265]*265za, 342 F.3d 462, 467 (6th Cir.2003); United States v. Guadarrama, 128 F.Supp.2d 1202, 1217 (E.D.Wis.2001).
This Court has recognized that society has become more violent, that attacks against law enforcement officers have become more prevalent, that there is a greater need for police to take protective measures to ensure their safety and that of the community that might have been unacceptable in earlier times, and that Terry has been expanded to accommodate those concerns. In In re David 367 Md. 523, 534, 789 A.2d 607, 613 (2002), we quoted with approval this passage from United States v. Tilmon, 19 F.3d 1221, 1224-25 (7th Cir.1994):
“The last decade has witnessed a multifaceted expansion of Terry, including the trend granting officers greater latitude in using force in order to neutralize potentially dangerous suspects during an investigatory detention. For better or worse, the trend has led to the permitting of the use of handcuffs, for the placing of suspects in police cruisers, the drawing of weapons and other measures of force more traditionally associated with arrest than with investigatory detention.”
Our approval of “hard takedowns” in David S. and in Lee v. State, 311 Md. 642, 537 A.2d 235 (1988), as permissible Terry detentions rather than as arrests, confirms our acceptance of that observation. See also Dashiell v. State, 374 Md. 85, 821 A.2d 372 (2003).
Cotton’s reliance on Detective Henning’s recitation of the Miranda warnings before questioning him as evidence that an arrest had already occurred also finds little support either in logic or in the case law. The prophylactic requirement of Miranda warnings is designed to safeguard important Fifth Amendment protections. See Dickerson v. United States, 530 U.S. 428, 120 S.Ct. 2326, 147 L.Ed.2d 405 (2000). Although the giving of those warnings may be considered along with more relevant factors as part of all that occurred, it should have no special significance in determining whether a temporary detention constitutes an arrest for Fourth Amend[266]*266ment purposes because it may well be required even when there is clearly no arrest.
Miranda warnings need to be given whenever there is a custodial interrogation, and a custodial interrogation can arise from a pure Terry stop that never crosses into an arrest. See United States v. Smith, 3 F.3d 1088 (7th Cir.1993), cert. denied, 510 U.S. 1061, 114 S.Ct. 733, 126 L.Ed.2d 696 (1994); United States v. Perdue, 8 F.3d 1455 (10th Cir.1993); United States v. Clemons, 201 F.Supp.2d 142 (D.D.C.2002); United States v. Calloway, 298 F.Supp.2d 39 (D.D.C.2003). Understanding that, courts have made clear that a cautious or gratuitous recitation of Miranda warnings is irrelevant to whether there has been an arrest, or even a custodial interrogation. Cummings v. State, 27 Md.App. 361, 341 A.2d 294 (1975); Sydnor v. State, 39 Md.App. 459, 387 A.2d 297 (1978); Com. v. Alicea, 376 Mass. 506, 381 N.E.2d 144, 149-50 (1978); People v. Wipfler, 68 Ill.2d 158, 11 Ill.Dec. 262, 368 N.E.2d 870 (1977); People v. Dozier, 67 Ill.App.3d 611, 24 Ill.Dec. 388, 385 N.E.2d 155, 158 (1979); and cf. United States v. Diaz-Lizaraza, 981 F.2d 1216, 1222 (11th Cir.1993).5 Indeed, if the police proceed to interrogate a person seized and temporarily detained pursuant to Terry and do not give Miranda warn[267]*267ings, any incriminating evidence revealed by that interrogation may, depending on the circumstances, be held inadmissible as the product of a custodial interrogation and thereby doom the validity of an ensuing arrest based on that evidence. The law should encourage police to give those warnings when questioning a suspect, not discourage them by regarding the warnings as converting a good Terry stop into a bad arrest.
In summary, Cotton’s reliance on the facts that he was handcuffed, placed under guard, and given Miranda warnings as establishing that he was de facto arrested either upon his initial detention or after fifteen to twenty minutes of it finds no substantial support in either Federal or this Court’s current jurisprudence. Acceptance of that view would place both police officers and innocent bystanders at considerable risk.
JUDGMENT OF COURT OF SPECIAL APPEALS AFFIRMED, WITH COSTS.