Maryland v. Garrison Case Brief

Why is the case important?

Police obtain a search warrant to search “the premises known as 2036 Park Avenue third floor apartment,” but discover after acquiring contraband that they were in defendant Garrison’s separate apartment.

Facts of the case

Baltimore police officers obtained a warrant for the apartment of Lawrence McWebb and “the premises known as 2036 Park Avenue third floor apartment.” When they obtained and executed the warrant, the police mistakenly believed that there was only one apartment on the third floor. By the time they discovered there were two apartments, the police were already in the process of searching the apartment of Harold Garrison. During that search, police discovered heroin. Garrison was tried and convicted of violating Maryland’s Controlled Substances Act. He filed a motion to suppress the evidence of the heroin discovered during the search, but the trial court denied the motion. The Maryland Court of Special Appeals affirmed, but the Maryland Court of Appeals reversed.

Question

Can the fruits of a search pursuant to a warrant not adequately describing the premises be excluded on Fourth Amendment grounds when the police officer who obtained it reasonably believed that the premises were described precisely?

Answer

No. Reverse and remand.
The warrant was valid when issued because such validity must be assessed on the basis of the information the officers disclose or have a duty to discover and disclose to the issuing magistrate.

Conclusion

The Supreme Court pf the United States reversed the judgment of the Court of Appeal of Maryland and remanded the case for further proceedings. The Court held that execution of a valid search warrant by police officers was consistent with a reasonable effort to ascertain and identify the place intended to be searched, within the meaning of the Fourth Amendment , even though the apartment they search was not the one occupied by the person named in the warrant. The scope of a lawful search was defined by the object of the search and the places in which there was probable cause to believe that it may be found. The Court further ruled that the objective facts available to the officers suggested no distinction between defendant’s apartment and the third-floor premises specified in the search warrant.

  • Case Brief: 1987
  • Petitioner: Maryland
  • Respondent: Harold Garrison
  • Decided by: Rehnquist Court

Citation: 480 US 79 (1987)
Argued: Nov 5, 1986
Decided: Feb 24, 1987
Granted Feb 24, 1986