Law School Case Brief
United States v. Griffith - 867 F.3d 1265 (D.C. Cir. 2017)
Probable cause to arrest a person will not itself justify a warrant to search his property. Regardless of whether an individual is validly suspected of committing a crime, an application for a search warrant concerning his property or possessions must demonstrate cause to believe that evidence is likely to be found at the place to be searched. Moreover, there must be a nexus between the item to be seized and the alleged criminal behavior.
Ezra Griffith was charged with unlawful possession of a firearm by a convicted felon. He moved to suppress the firearm, arguing that police discovered it while executing an invalid warrant to search his home. The warrant authorized officers to search for and seize all cell phones and other electronic devices in Griffith's residence. The supporting affidavit, however, offered almost no reason to suspect that Griffith in fact owned a cell phone, or that any phone or other device containing incriminating information would be found in his apartment. The district court denied the motion, and a jury convicted Griffith at trial. Thereafter, Griffith challenged the district court’s decision denying his motion to suppress. Conversely, the Government argued that even if the warrant was invalid, the firearm still need not have been excluded from the evidence against Griffith.
Was the warrant executed by the police officers in order to search Griffith’s home invalid?
The Court held that a warrant authorizing officers to search for and seize all cell phones and other electronic devices in Griffith’s residence was unsupported by probable cause because the supporting affidavit offered almost no reason to suspect that Griffith in fact owned a cell phone, or that any phone or other device containing incriminating information would be found in his apartment, and the fact that most people carried a cell phone was not enough to justify the search. Furthermore, the Court ruled that the warrant was invalid because of its overbreadth in allowing the seizure of all electronic devices found in the residence. According to the Court, once the police asserted authority to search the home pursuant to an invalid warrant, evidence relinquished in response to the officers' announcement was unlawfully obtained. Thus, the Court ruled that the firearm abandoned in response to the police's announcement of an invalid search warrant had to be suppressed.
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