Murray v. United States Case Brief

Why is the case important?

Two agents trailing the petitioner forced entry into a warehouse containing the petitioner’s vehicle. They discovered marijuana. Subsequently, they returned with a warrant.

Facts of the case

“On April 6, 1983, federal law enforcement agents tailing Michael F. Murray and James D. Carter for suspicion of illegal drug activities saw the two drive large vehicles into a warehouse in South Boston. When Murray and Carter left, the agents saw a tractor-trailer rig and a large container. The agents arrested Murray and Carter and lawfully seized their vehicles, which contained marijuana. Several agents then returned to the warehouse, forced entry without a search warrant, and found numerous wrapped bales of what was later confirmed to be marijuana. The agents did not disturb the bales and kept the warehouse under surveillance until they obtained a search warrant. In applying for the search warrant, the agents did not mention the unwarranted entry or the information they had obtained. Approximately eight hours later, the agents obtained the warrant, entered the warehouse, and seized the bales along with the notebooks indicating the destinations of the marijuana.Before the trial, Murray and Carter moved to suppress the evidence discovered in the warehouse and argued that the warrant was invalid because it was based on information obtained in the previous unwarranted entry. The district court denied the motion and the U.S. Court of Appeals for the First Circuit affirmed.”

Question

Whether, . . . assuming evidence obtained pursuant to an independently obtained search warrant, the portion of such evidence that been observed in plain view at the time of a prior illegal entry must be suppressed.

Answer

No. The court applied the independent source rule formulated in Segura, permitting evidence found independently, despite an improper search. In the present case, knowledge that the marijuana was in the warehouse was assuredly acquired at the time of the unlawful entry. But it was also acquired at the time of entry pursuant to the warrant, and if the later acquisition was not the result of the earlier entry, there is no reason why the independent source doctrine should not apply. This was applied to the tangible evidence: the bales. However, the court was uncertain as to whether the search pursuant to the warrant was in fact a genuinely independent source of the information and tangible evidence at issue here. The agents did not reveal the original search to the magistrate issuing the warrant. Thus, they remanded to the Court of Appeals with instructions that it remand to the District Court for determination whether the warrant-authorized search of the warehou
se was an independent source of the challenged evidence in the sense the court described.

Conclusion

The ultimate question is whether the search pursuant to warrant was in fact a genuinely independent source of the information and tangible evidence at issue. This would not have been the case if the agents’ decision to seek the warrant was prompted by what they had seen during the initial entry or if information obtained during that entry was presented to the Magistrate and affected his decision to issue the warrant. Because the District Court did not explicitly find that the agents would have sought a warrant if they had not earlier entered the warehouse, the cases are remanded for a determination whether the warrant-authorized search of the warehouse was an independent source in the sense herein described.

  • Case Brief: 1988
  • Petitioner: Michael F. Murray
  • Respondent: United States
  • Decided by: Rehnquist Court

Citation: 487 US 533 (1988)
Argued: Dec 8, 1987
Decided: Jun 27, 1988