Massachusetts v. Sheppard

Massachusetts v. Sheppard Case Brief

United States Supreme Court
468 U.S. 981 (1984)

ISSUE: Did officers reasonably rely on a search warrant issued by a judge that was defective because it included a authorization to search for materials for which the officers had no PC and it didn't incorporate the supporting affidavit?
HOLDING: Yes.
FACTS:
  • A body was found, and police questioned V's boyfriend, D
  • D said that he was at a gaming place that night, but it turns out that he was gone for a 2-hour period when he borrowed someone's car
  • The car was searched and blood stains and wire similar to that found near the body were found
  • A search warrant was prepared on a controlled substances search warrant application, and some changes were made
  • A judge then made changes of his own and issued the warrant without changing the reference to controlled substances and w/o incorporating the affidavit
PROCEDURAL HISTORY:
  • Trial judge concluded that the warrant failed the 4th Amdt., but nevertheless held that the officers acted in good faith and allowed the evidence in
  • Mass. SJC reversed
REASONING:
  • Reasonable belief: No dispute that the officers believed that the warrant was valid, and there was an objectively reasonable basis for the officers' mistaken belief
    • Reasonable police officer could conclude that the warrant authorized a search for those items contained in the warrant
    • Officers are not required to disbelieve a judge how had advised an officer and assured him that it authorized the search
    • Police conduct was reasonable and largely error-free
COMMENTS:
  • Should fall under Leon particularity exception to good-faith exception to Exclusionary Rule
  • BUT, no police misconduct to deter, so no exclusion
    • Judicial mistake = no suppression
OTHER CASES:
  • Illinois v. Krull: Evidence obtained as a result of a constitutionally unreasonable search was admissible because the officers reasonably relied on a state statute authorizing such search
    • No police error to deter
  • Arizona v. Evans: Evidence found as the result of an unreasonable arrest is admissible if the officer acted in objectively reasonable reliance on an erroneous computer record incorrectly indicated an outstanding arrest warrant and if court employees are responsible for the erroneous record

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