Groh v. Ramirez case brief

Groh v. Ramirez case brief summary
540 U.S. 551 (2004)

CASE SYNOPSIS

Petitioner federal agent sought a writ of certiorari to the United States Court of Appeals for the Ninth Circuit, challenging the decision that a search of respondent individuals' home was unconstitutional and that the federal agent was not entitled to qualified immunity. Certiorari was granted to address the constitutionality of the search and the availability of qualified immunity.

ISSUE
The issues were whether the search violated the Fourth Amendment, and if so, whether the federal agent was entitled to qualified immunity, given that a magistrate, relying on an affidavit that particularly described the items in question, found probable cause to conduct the search.


DISCUSSION

• The warrant was plainly invalid as it provided no description of the type of evidence sought. 
• The fact that the application adequately described the things to be seized did not save the warrant from its facial invalidity because the warrant did not incorporate other documents by reference and neither the affidavit nor the application accompanied the warrant. 
• The magistrate's authorization of the search did not render it constitutional because the warrant's obvious deficiency required the court to consider the search warrantless and presumptively unreasonable. 
• The federal agent was not entitled to qualified immunity because no reasonable officer could have believed that a warrant that plainly did not comply with the Fourth Amendment's particularity requirements was valid nor been unaware of the basic rule that, absent consent or exigency, a warrantless search was presumptively unconstitutional.

CONCLUSION
The judgment was affirmed.


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