Course: Introduction / Procedural Law
Maryland v. Garrison (1987) is a landmark SCOTUS decision in which the Court established a “good faith” exception to the exclusionary rule when police acted in reliance on a faulty warrant that they reasonably believed to be valid.
Maryland v. Garrison is a significant case in the history of criminal justice, as it established a good faith exception to the exclusionary rule. Prior to this case, evidence obtained by law enforcement in violation of the Fourth Amendment was typically excluded from the trial. However, the Court recognized that there may be circumstances in which police officers act in good faith, and as such, the exclusionary rule should not apply.
The case arose when police officers executed a search warrant at a building they believed to contain a single apartment. However, they soon discovered that there were two separate apartments, and they had mistakenly searched the wrong apartment. The officers had relied on a warrant that contained a technical error in the address, and they had acted in good faith based on the information they had at the time.
The defendants argued that the evidence seized during the search should be suppressed, as it had been obtained in violation of the Fourth Amendment. The trial court agreed, but the decision was later overturned on appeal. The case eventually made its way to the Supreme Court.
In a 6-3 decision, the Court held that evidence obtained during a search conducted in good faith, but in violation of the Fourth Amendment, may be admissible in court. The Court recognized that the exclusionary rule was designed to deter police misconduct but that it also had the potential to exclude relevant and reliable evidence. Therefore, the Court created a “good faith” exception to the exclusionary rule, stating that when police officers act in good faith reliance on a warrant, and a neutral and detached magistrate made the error, the evidence seized during the search can be admitted in court.
The decision in Maryland v. Garrison has been praised by some for allowing courts to consider the good faith of police officers and for preventing the exclusion of evidence that was obtained in good faith. However, it has also been criticized by others for potentially undermining Fourth Amendment protections and allowing evidence to be admitted even when it was obtained through an unlawful search or seizure.
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Last Modified: 04/08/2023