Search-warrant particularity; Place to be searched; People v Hampton; Good-faith exception; United States v Leon

The court held that the warrant failed the Fourth Amendment’s particularity requirement because it did not describe defendant’s residence with enough specificity to allow officers to identify the correct premises with reasonable effort and created a reasonable probability that another residence would be searched. It also held that the good-faith exception did not apply because the warrant was so facially deficient that no reasonable officer could presume it valid. Officers sought a warrant to investigate alleged jury tampering after “Jury Nullification” pamphlets appeared near a courthouse entryway, and the affidavit tied the handwriting to defendant, a convicted felon living at a specific address. The warrant authorized a search of the “residence, property, all vehicles, and out-buildings” at that address and described the residence as “several trailers behind pine[] trees” and “2 white and brown trailer style residences.” When executing the warrant, officers approached and entered the wrong trailer first, briefly detaining two occupants, before realizing the mistake and moving to a different trailer where they seized electronic devices, a “Jury Nullification” letter, and firearms and ammunition. On appeal, the court applied the two-part test that the description must enable officers to locate the intended premises with reasonable effort and must avoid a reasonable probability that another premises might be searched. It concluded the warrant’s description was inadequate because the property contained multiple distinct residences with separate addresses, the mailboxes at the driveway entrance visibly reflected that fact, and the warrant “lumped together” the trailers and left officers to guess which was defendant’s. The panel emphasized that the address alone did not cure the ambiguity when the warrant authorized a search of the entire property and described multiple trailers in a way that “essentially created a coin-flip situation,” which the execution confirmed by the initial mistaken search. The court rejected reliance on multi-unit-building cases because this involved separate structures and readily observable indicators of multiple residences. It also held Leon’s good-faith exception was unavailable because the warrant was “so facially deficient” in particularizing the place to be searched that officers could not reasonably presume it valid, especially given the missed obvious signs and the minimal investigation. Affirmed.