Maryland v. Garrison

Background

Police in Baltimore obtained a warrant to search Lawrence McWebb and "2036 Park Avenue third floor apartment." Officers reasonably believed the third floor was a single apartment occupied by McWebb. In fact, there were two separate third-floor units; respondent Garrison lived in the other unit. When officers executed the warrant using McWebb's key, they entered the third-floor area, saw open doors to both units, and searched what they thought was McWebb's apartment. They discovered heroin, cash, and paraphernalia in Garrison's unit before realizing the third floor had two apartments. Trial court denied suppression, an intermediate court affirmed, Maryland's highest court reversed, and the Supreme Court granted review.

Reasoning

The Court separated two issues: whether the warrant was valid and whether the manner of execution was reasonable. It held the warrant valid based on the information the officers had and reasonably believed when they applied. The Court found the officers' mistake about the building layout was objectively understandable and that executing the warrant under that reasonable belief justified the search and seizure until the officers discovered the separate unit. The Court emphasized officers must stop searching once they learn a unit is excluded.

Real world impact

The decision affects searches in multiunit buildings. It permits evidence seized when officers make a reasonable, good-faith mistake about which unit a warrant covers. It also emphasizes police duty to limit searches once they learn a warrant mistakenly includes another dwelling; failing to do so can invalidate further intrusion.

Dissents or concurrances

Justice Blackmun (joined by Justices Brennan and Marshall) dissented, arguing the search of Garrison's apartment was warrantless and unreasonable and that officers should have taken further steps to identify the correct unit.