Background
Federal agents suspected Ryan Dales of wire fraud and obtained a warrant to search his Baltimore apartment based on an affidavit. The search yielded evidence of other crimes, leading to Dales’s indictment. Dales moved to suppress the evidence, arguing the affidavit lacked probable cause. The district court denied the motion, ruling the affidavit established probable cause and that the good-faith exception applied in the alternative.
The court’s reasoning
The court reviewed the denial of the motion to suppress de novo. It held that the good-faith exception precludes suppression when law enforcement relies on a warrant in an objectively reasonable manner. The exception does not apply only if a reasonably well-trained officer would have known the search was illegal because the warrant was facially deficient. The court found the warrant was not so facially deficient that the executing officers could not reasonably presume it was valid.
What it means going forward
Law enforcement officers may continue to rely on search warrants that are not facially deficient without fear of suppression, even if the warrant is later found to be technically deficient.