Maryland v. Garrison
480 U.S. 79, 107 S. Ct. 1013, 94 L. Ed.2d 72 (1987)

  • The police obtained a search warrant to search a guy named Webb and “the premises known as 2036 Park Avenue third floor apartment.”
    • At the time, the police believed that there was only one apartment on the third floor, owned by Webb.
  • When the police got there, they found two apartments on the third floor. Webb’s apartment and Garrison’s apartment. Without realizing that they were separate, they searched Garrison’s apartment and found some drugs.
    • As soon as the police realized they weren’t in Webb’s apartment, they stopped the search, but drugs had already been found.
  • Garrison was arrested and charged with drug possession.
  • The Trial Court convicted Garrison of drug possession. He appealed.
    • Garrison argued that the search warrant was insufficient because the 4th Amendment requires that that the warrant must “particularly describe the place to be searched.” In this case, it just said “third floor”, which did not fully describe Garrison’s apartment.
    • The prosecution argued that the warrant was to search the entire third floor, so it was perfectly valid.
  • The Appellate Court upheld the conviction. Garrison appealed.
  • The Maryland Supreme Court reversed and granted Garrison’s motion to suppress the evidence. The prosecutor appealed.
    • The Maryland Supreme Court found that the warrant did not authorize a search of Garrison’s apartment and the police had no justification for making a warrantless entry into his premises.
  • The US Supreme Court reversed the Maryland Supreme Court and found that the warrant was valid.
    • The US Supreme Court found that the police reasonably believed that they were searching Webb’s apartment. It was just an honest mistake.
    • The Court found that the warrant did “particularly describe” the place to be searched, it was just a little broader than it needed to be. Therefore it was still a valid warrant.
      • That part of the 4th Amendment was designed to protect against wide-ranging and exploratory searches, and that wasn’t the allegation here.
      • The Court found that the discovery of facts demonstrating that a valid warrant was unnecessarily broad does not retroactively invalidate the warrant.
      • See United States v. Leon (468 U.S. 897 (1984)), which also held that the exclusion doctrine is not the appropriate remedy for an honest mistake.
      • Because warrants could never be based on information that was guaranteed to be true, courts have held that they are still valid even when predicated on information that turns out to be false, as long as it was reasonable to believe that the information was true at the time the warrant was issued.
    • The Court found that the warrant was executed in a reasonable manner. Even though a mistake was made, the police were acting to the best of their ability and according to the information they had at the time. Therefore the search was legal.
  • In a dissent, it was argued that the warrant was pretty clearly designed to search only Webb’s apartment, and so evidence that was not found in Webb’s apartment should be excluded because it was an unreasonable search and seizure without a valid warrant.
    • The dissent further argued that it should have been pretty easy to figure out that there were two apartments on the third floor, so it was not an honest mistake, it was sloppy policework and therefore not reasonable.
  • In the case of Groh v. Ramirez (540 U.S. 551 (2004)), it was held that when there was a clerical error and the warrant was not filled out correctly the warrant is invalid and the search is unconstitutional.
    • That may seem at odds with this decision, but the difference is that the formality insures that the magistrate has actually read the warrant and has based his decision on the correct information. In addition, it lets the home owner know the scope of the search.
      • A search predicated in incorrect research is still reasonable, a search predicated on an typo is not reasonable.