Search Warrants
Overview of Search Warrants
Discussion of search warrants including:
How they are written
How they are obtained
What they specify
Fourth Amendment Context
The language of the Fourth Amendment:
Describes rights individuals have without defining terms.
Does not specifically mention 'privacy' but implies a right to privacy.
General rule of privacy:
Individuals are guaranteed rights to keep personal effects from governmental inquiry unless government has a compelling reason to intrude.
Probable Cause
Essential concept in search and seizure:
Defined through the case Carroll v. United States (1925), dealing with transporting untaxed alcohol.
Probable cause is defined when officers have trustworthy information indicating reasonable belief of criminal activity.
Rises above a mere hunch but is less than proof beyond a reasonable doubt.
Must be based on an objective standard rather than a subjective belief of an officer.
Legal searches can occur without a warrant if probable cause exists, but warrantless searches of homes are presumed unreasonable under the Fourth Amendment.
Warrantless searches of cars or open fields are generally allowed under the theory that there's reduced expectation of privacy.
Exceptions to Warrant Requirement
Various circumstances allow warrantless searches including:
Searches incident to arrest
Searches based on consent
Inventory searches
Emergency searches
Obtaining a Search Warrant
To obtain a search warrant under the Fourth Amendment:
Description must be specific concerning the object to be seized.
Specific location of the object must also be included.
Specificity Example:
A warrant to search a specific computer for child porn allows a search of all related computers within the defendant's control.
A properly specific description could allow the search of a garage or business area if probable cause is established.
Minor errors in description typically do not invalidate a search warrant under most circumstances.
Example: A court upheld a description of a rural trailer that contained minor errors but was still sufficiently detailed.
Description Criteria:
Need not be perfect, but must be detailed.
For example, searching for a stolen firearm might require specifications like:
Serial number
Caliber
Type
Manufacturer
The Search Warrant Process
Initial Steps:
The police officer determines probable cause based on facts and circumstances.
An affidavit is prepared detailing the operative facts which must be sworn as true.
Informants:
Information from informants must include facts that validate their credibility.
Judge evaluates the probable cause independently and may sign the warrant if deemed appropriate.
Execution of Search Warrant:
Warrant is a court order directing law enforcement to search for specific property and return it to the court.
Requirement to notify the individual being searched of the warrant; receipt for seized items must be provided.
Return Process:
Officers must submit the returned warrant and a written inventory to the court.
Judges provide a copy of the inventory to the individuals whose property was seized.
Legal Authority and Restrictions
A search warrant is directed toward law enforcement officials and must state detailed reasons and descriptions of where and what to search.
Individuals upon whom the warrant is executed must allow the search but do not have to assist law enforcement.
Execution Rules
Time Limits:
Warrant execution must occur within a reasonable timeframe as dictated by state law.
Best practice is to execute warrants during daylight hours; night execution is allowed in many jurisdictions without invalidation of the search.
Knock and Announce Rule
Legal requirement under the Fourth Amendment mandates officers to knock and announce before entering.
This can be bypassed for officer safety or if not feasible.
Case Example: Hudson v. Michigan
Officers violating knock and announce still had evidence obtained upheld as lawful, even without suppressing the evidence.
During the Execution of a Search Warrant
Police may detain individuals present but cannot conduct personal searches unless permitted by law.
Police can restrict reentry to premises while waiting for a warrant if they have probable cause.
Understanding the Scope of a Search
The scope of a search is defined by the object being searched for and its reasonable storage locations.
Example:
Powdered drugs can be hidden anywhere, thus broader search areas are permissible.
However, a large object like a rifle cannot be stored in restricted areas like a glove box or a medicine cabinet.
Important Judicial Input:
Justice Stevens on scope definition highlighted that object location must align with probable cause.
Example: Warrant to search for lawnmower cannot logically support a search of an unrelated upstairs bedroom.
Reasonableness is critical; searches in areas unlikely to yield the object may be unconstitutional and evidence could be excluded.
Future Discussions
The topic of searches will continue with a focus on details mentioned throughout this guide.