Tuesday, November 5, 2013

Maryland v. Garrison case brief

Maryland v. Garrison case brief summary
480 U.S. 79 (1987)

Defendant was convicted of violating Maryland's Controlled Substances Act after marijuana and related paraphernalia were discovered in his apartment. Defendant filed a motion to suppress the evidence seized from his apartment, which was denied by the trial court. The state court of special appeals affirmed, but the Court of Appeals of Maryland reversed and remanded with instructions to remand the case for a new trial. Certiorari was granted.

The evidence had been seized in a search conducted pursuant a warrant that specified a location of "the premises known as 2036 Park Avenue third floor apartment." The police reasonably believed that there was only one apartment on the premises described in the warrant. However, there were two apartments on the third floor. Before the officers executing the warrant became aware that they were in a separate apartment occupied by defendant, they had discovered the contraband that provided the basis for defendant's conviction.

The question presented to the Court was whether the seizure of the contraband was prohibited by the Fourth Amendment.

The Court held that the warrant was valid when it was issued and the manner in which it was executed was reasonable.

  • The validity of the warrant was assessed on the basis of the information that the officers disclosed, or had a duty to discover and to disclose, to the issuing magistrate. 
  • The officers' execution of the warrant reasonably included the entire third floor, and their conduct was consistent with a reasonable effort to ascertain and identify the place intended to be searched within the meaning of the Fourth Amendment.


The Court reversed the judgment of the state court of appeals and remanded the case for further proceedings not inconsistent with the Court's opinion.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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