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People v. Amador, 24 Cal.4th 387, 9 P.3d 993, 100 Cal.Rptr.2d 617, 00 Cal. Daily Op. Serv. 8412, 2000 Daily Journal D.A.R. 11,203

Facts

Detective Grant Gulickson executed a search warrant on a house where the defendant lived, based on information from an informant who had pointed out the residence. The warrant contained inaccuracies regarding the address and the number of stories of the house. Despite these errors, the detective had personally observed the house and executed the warrant on the correct premises, leading to the seizure of illegal items.

On February 26, 1997, Detective Grant Gulickson and another City of Brea police officer executed a search warrant on a house in which defendant lived. About five to six weeks earlier, an informant had pointed the house out to Detective Gulickson and another detective as the three drove by it.

Issue

Whether the inaccuracies in the search warrant's description of the premises required suppression of the evidence obtained during the search.

We must decide whether these differences require suppression of the evidence the officer obtained in the search.

Rule

A search warrant must particularly describe the place to be searched, but complete precision is not required. The description must enable the executing officer to locate and identify the premises with reasonable effort.

A search warrant must “particularly describ[e] the place to be searched.” (U.S. Const., 4th Amend.; Cal. Const., art. I, § 13; see also Pen.Code, § 1525.)

Analysis

The court found that the executing officer was able to locate the correct premises despite the inaccuracies in the warrant. The officer's personal knowledge of the house, having been shown it by the informant, mitigated the risk of mistakenly searching another property. The court emphasized that the warrant's description, while flawed, was sufficient to uphold the search.

Applying these rules to this case, we find the executing officer was easily able to locate and identify the specified premises, and there was little probability that another premise would be mistakenly searched.

Conclusion

The Supreme Court reversed the Court of Appeal's decision and upheld the validity of the search warrant, allowing the evidence obtained to be admissible.

Accordingly, we reverse the judgment of the Court of Appeal, which ordered the evidence suppressed.

Who won?

The State prevailed in the case as the Supreme Court upheld the search warrant's validity, concluding that the inaccuracies did not warrant suppression of the evidence.

The Supreme Court reversed the Court of Appeal's decision and upheld the validity of the search warrant, allowing the evidence obtained to be admissible.

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