Law School Case Brief
United States v. Martin - 399 F.3d 879 (7th Cir. 2005)
The Fourth Amendment's rules for warrants do not include time limits.
After receiving information that defendant Leland Martin had acquired guns and dynamite in preparation for robbing a bank, law enforcement agents arrested defendant pursuant to a warrant for an unrelated offense. Once the agents arrived with a warrant, both defendant and his wife consented to a search of their home. There, the agents found a gun and ammunition. After trial in federal district court, defendant was convicted under 18 U.S.C.S. § 922(g)(1) based on the gun and ammunition found in the search of the home. Defendant appealed, arguing that the consents were invalid because the agents acted pursuant to a stale warrant and thus had no right to be at defendant's home in the first place.
Did the agents act pursuant to a stale warrant and therefore had no right to be at defendant's home?
The appellate court affirmed the trial court's judgment. The court held that whether the arrest warrant had expired pursuant to Ind. Code § 35-33-2-4 was irrelevant. According to the Court, the Fourth Amendment did not include time limits, and the exclusionary rule was limited to violations of the Fourth Amendment. In the case at bar, defendant did not deny that the warrant satisfied all the express requirements of the Fourth Amendment. The timeliness of a warrant could affect reasonableness under the Fourth Amendment, but before they executed the warrant, the agents verified that defendant was still a fugitive. Thus, the court concluded that the warrant was constitutionally valid and its execution was reasonable.
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