Maryland v. Garrison
480 U.S. 79 (1987)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The validity of a search warrant must be assessed based on the information the police disclosed or had a duty to discover at the time the warrant was issued. Evidence obtained during the execution of a warrant that is later found to be overly broad due to a reasonable factual mistake is not subject to the exclusionary rule if the officers' execution of the warrant was also objectively reasonable.
Facts:
- Baltimore police received information from a reliable informant that Lawrence McWebb was selling illegal drugs in his third-floor apartment at 2036 Park Avenue.
- A police detective investigated by examining the building's exterior and inquiring with the local utility company.
- Based on this investigation, the detective reasonably concluded that the third floor contained only one apartment, occupied by McWebb.
- The police obtained a warrant to search the person of McWebb and "the premises known as 2036 Park Avenue third floor apartment."
- While executing the warrant, officers encountered McWebb outside the building and used his key to access the third-floor landing.
- On the landing, officers saw Harold Garrison standing in a vestibule area between two open apartment doors, but they believed the entire floor was one unit.
- Acting on this belief, officers entered Garrison's apartment and discovered heroin, cash, and drug paraphernalia.
- Only after discovering the contraband did the officers realize that the third floor was divided into two separate apartments, at which point they immediately ceased their search of Garrison's unit.
Procedural Posture:
- Garrison's motion to suppress the seized evidence was denied by the state trial court.
- Garrison was convicted, and the Maryland Court of Special Appeals (an intermediate appellate court) affirmed the trial court's ruling.
- The Court of Appeals of Maryland (the state's highest court) reversed the conviction, holding that the search of Garrison's apartment was unconstitutional.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals of Maryland.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Fourth Amendment prohibit the seizure of contraband discovered by police during the search of an apartment that was erroneously included in a search warrant due to the officers' reasonable but mistaken belief that the entire floor of a building constituted a single apartment?
Opinions:
Majority - Justice Stevens
No. The seizure of the contraband did not violate the Fourth Amendment because the officers' actions were based on a reasonable, albeit mistaken, belief about the scope of the premises to be searched. First, the warrant itself was valid when issued. Its validity must be judged based on the information the officers had at the time of application, and their conclusion that the third floor was a single apartment was reasonable after a diligent inquiry. The subsequent discovery of facts demonstrating the warrant was overly broad does not retroactively invalidate it. Second, the execution of the warrant was reasonable. The officers' failure to realize the overbreadth of the warrant was objectively understandable, as the objective facts available to them at the time suggested no distinction between the two apartments. Citing Hill v. California, the Court recognized the need to allow latitude for honest mistakes by officers, and since the search was discontinued as soon as the mistake was discovered, the officers' conduct was consistent with a reasonable effort to comply with the Fourth Amendment.
Dissenting - Justice Blackmun
Yes. The search of Garrison's apartment violated the Fourth Amendment because it constituted a warrantless search of a home, for which no exception applied. The warrant specifically authorized a search of McWebb's apartment, not the entire third floor, and the police exceeded that scope by entering Garrison's separate residence. Furthermore, even if analyzed under a reasonableness standard, the officers' mistake was not reasonable. The officer obtaining the warrant should have conducted a more thorough investigation, as the presence of seven mailboxes and bells on the building's exterior indicated it was a multi-unit dwelling, requiring greater care to specify the target unit. The officers executing the warrant also acted unreasonably by failing to realize their mistake sooner, given their observation of the mailboxes, their encounter with Garrison in a separate space, and the symmetrical layout of the two apartments which should have been apparent during an initial security sweep.
Analysis:
This decision establishes the 'reasonable mistake' doctrine in the context of executing search warrants, giving police a degree of latitude when they act on good-faith factual errors. It clarifies that the Fourth Amendment's reasonableness standard applies not only to the probable cause determination but also to the officers' understanding of the physical layout of the premises being searched. The case is significant for balancing the particularity requirement against the practical realities of police work, holding that an objectively understandable mistake about the scope of a warrant does not automatically trigger the exclusionary rule. This precedent impacts future cases involving searches of multi-unit dwellings by focusing the inquiry on the reasonableness of the officers' investigation and conduct rather than on the absolute accuracy of the warrant.
Unlock the full brief for Maryland v. Garrison