Maryland v. Garrison - Significance, Latitude For Honest Mistakes Made By Officers, Evidence Against The Victim Of Police Error Should Not Be Used

court petitioner warrant congressional

Petitioner

State of Maryland

Respondent

Garrison

Petitioner's Claim

That evidence taken from Garrison's apartment should not be suppressed even though the police officers used an overbroad warrant.

Chief Lawyer for Petitioner

Stephen H. Sacks, Attorney General of Maryland

Chief Lawyer for Respondent

Gerald A. Kroop

Justices for the Court

Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist, Antonin Scalia, John Paul Stevens (writing for the Court), Byron R. White

Justices Dissenting

Harry A. Blackmun, William J. Brennan, Jr., Thurgood Marshall

Place

Washington, D.C.

Date of Decision

24 February 1987

Decision

Reversed the Maryland Court of Appeals ruling and held that the search warrant was valid and the execution of the warrant did not violate Garrison's rights under the Fourth Amendment, since the mistake made by the officers was understandable and reasonable.

Related Cases

Steele v. United States, 267 U.S. 498 (1925).
Brinegar v. United States, 338 U.S. 160 (1949).
Hill v. California, 401 U.S. 797 (1971).
Coolidge v. New Hampshire, 403 U.S. 443 (1971).

Sources

Levy, Leonard W., ed. Encyclopedia of the American Constitution. New York: Macmillan, 1986.

Maryland v. Garrison - Significance

The ruling provided another good faith exception to the exclusionary rule. The use of an overly broad warrant did not justify the exclusion of evidence from trial because the officers made a reasonable effort to identify the place intended for search. On 21 May 1982 Baltimore police officers obtained a warrant to search Lawrence McWebb and a 2036 Park Avenue third floor apartment. Although there w…

Maryland v. Garrison - Latitude For Honest Mistakes Made By Officers

The Supreme Court agreed to hear the case, noting that it involved two separate constitutional issues--the validity of the warrant and the reasonableness of its execution. In his written opinion, Justice Stevens noted that the warrant clause of the Fourth Amendment prohibits the issuance of a general warrant. Instead, the warrant must describe the place to be searched and the persons or things to …

Maryland v. Garrison - Evidence Against The Victim Of Police Error Should Not Be Used

Justice Blackmun wrote the dissent. Blackmun believed that the search violated the Fourth Amendment and that the evidence should have been suppressed. Regarding the search of apartments in multi-unit buildings, courts have found invalid those warrants that do not describe the targeted unit with enough specificity to prevent a search of all the units in the building. Blackmun and the court of appea…

Maryland v. Garrison - The Good Faith Exception

The exclusionary rule was developed to enforce Fourth Amendment search and seizure requirements in its exclusion from the criminal courtroom of evidence obtained by other than legal means. The good faith exception to the exclusionary rule, on the other hand, offers law-enforcement officers an area of leeway--opponents would call it a loophole--within the legal confines of the exclusionary rule. Th…

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