People v. Amador
100 Cal. Rptr. 2d 617, 9 P.3d 993, 24 Cal.4th 387 (2000)
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Rule of Law:
A search warrant containing factual inaccuracies in its description of the premises is valid under the Fourth Amendment's particularity requirement if the description is sufficient to allow an officer to identify the intended place with reasonable effort and there is no reasonable probability of another premise being mistakenly searched. The executing officer's prior personal knowledge of the correct location is a key factor in assessing this probability.
Facts:
- An informant drove with Detective Grant Gulickson and another detective and pointed out a house allegedly involved in criminal activity.
- The other detective took notes on the house's description and address.
- Relying on his partner's notes, Detective Gulickson prepared an affidavit and obtained a search warrant.
- The warrant described the target location as a two-story residence at "10817 Leland" in Santa Fe Springs.
- The actual house pointed out by the informant was a one-story residence located at "10811 Leland."
- Detective Gulickson, who had previously seen the house, personally executed the search warrant.
- Gulickson located and searched the correct house—the one the informant had identified—despite the descriptive errors in the warrant.
- During the search, officers found methamphetamine, a firearm, and materials for making fraudulent credit cards.
Procedural Posture:
- Defendant filed a motion to suppress evidence in the superior court (trial court).
- The trial court denied the motion to suppress.
- Following a court trial, the defendant was found guilty on multiple charges.
- Defendant, as appellant, appealed the conviction to the California Court of Appeal (an intermediate appellate court).
- The Court of Appeal reversed the trial court's judgment, ordering the evidence suppressed.
- The Attorney General, on behalf of the People as petitioner, sought and was granted review by the Supreme Court of California.
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Issue:
Does a search warrant that contains multiple factual inaccuracies in its description of the premises to be searched violate the Fourth Amendment's particularity requirement when the affiant-officer personally knows the correct location and searches the intended premises?
Opinions:
Majority - Chin, J.
No. A search warrant is not invalid due to descriptive inaccuracies if it is particular enough to prevent a mistaken search of the wrong premises. The Fourth Amendment's particularity requirement is meant to prohibit general, exploratory searches, not to punish 'deficient police draftsmanship.' Here, the warrant contained other correct descriptive details, and critically, the officer who obtained the warrant based on his personal observation also executed it. This personal knowledge ensured the correct house was searched, minimizing the risk of error and satisfying the purpose of the particularity clause.
Concurring - Mosk, J.
No. While the warrant in this case was sufficiently particular to be valid, the court should not rely on the executing officer's personal knowledge to cure an otherwise deficient description. A warrant's validity must be judged on its face to determine if it allows any officer to find the correct location, not just the one who happens to be the affiant. The fortuity that the knowledgeable officer executed the search does not negate the inherent risk posed by an inaccurate warrant.
Analysis:
This decision reinforces that the Fourth Amendment's particularity requirement is judged by a practical, common-sense standard rather than a hypertechnical one. It establishes that an executing officer's personal knowledge of the target location is a crucial factor in upholding a search warrant that contains descriptive errors. This precedent gives law enforcement a degree of leeway for good-faith mistakes in warrant drafting, but it also raises concerns, as noted in the concurrence, that it might dilute the requirement that a warrant be sufficient on its face.
