Murray v. United States case brief

Murray v. United States case brief summary
487 U.S. 533 (1988)

CASE SYNOPSIS

In separate district court cases below, petitioners were convicted of conspiracy to possess and distribute illegal drugs. The United States Court of Appeals for the First Circuit affirmed the district court decisions denying petitioners' motions to suppress evidence they alleged was illegally seized. Upon the grant of writs of certiorari, petitioners sought review of those judgments, and the Court consolidated the cases for review.

CASE FACTS
Petitioners' motions to suppress were based on claims that evidence was seized illegally because agents did not inform the magistrate about a prior warrantless entry to the premises where bales of marijuana were eventually seized. Petitioners contended that the independent source doctrine only applied to evidence obtained for the first time during an independent and lawful search.

DISCUSSION

• The Court rejected that argument and adopted the Government's view that the doctrine also applied to evidence initially discovered during, or as a consequence of, an unlawful search, if later obtained independently from activities untainted by the initial illegality. 
• Invoking the exclusionary rule in such circumstances would have put the police in a worse position than they would have been if no violation had occurred. 
• The Court held that, although the district court found that the agents did not reveal their warrantless entry to the magistrate, it did not explicitly find that the agents would have sought a warrant if they had not earlier entered the premises. 
• The Court remanded the cases for further findings as to whether the information upon which the warrant was based amounted to an independent source.

CONCLUSION
The Court vacated the judgment of the circuit court and remanded petitioners' cases with instructions that the circuit court remand to the district court for determination of whether the warrant-authorized search of the warehouse was an independent source of the challenged evidence.



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