Maryland v. Garrison
Citation and Court
480 U.S. 79 (1987) — Supreme Court of the United States
Facts
Officers obtained a warrant to search the third-floor apartment of Lawrence McWebb for drugs. Unknown to the officers, the third floor actually contained two separate apartments. Officers executed the warrant in Garrison’s apartment (the wrong one) before realizing their mistake, and found heroin and cash.
Issue
Whether a warrant and search based on an officer’s reasonable but mistaken belief about the layout of premises is valid under the Fourth Amendment.
Holding
The warrant and search were valid; the officers’ reasonable mistake about the apartment layout did not render the warrant defective or the search unconstitutional.
Rule / Doctrine
The validity of a warrant is assessed based on the information available to officers at the time it was obtained. If officers act with objective reasonableness in obtaining and executing the warrant, an honest mistake about the physical layout of premises does not require suppression of evidence found before the mistake is discovered.
Significance
Extends the reasonableness standard to factual mistakes in warrant execution. Officers are not held to a standard of perfection; if the mistake was objectively understandable given available information, the search remains valid.