Massachusetts v. Sheppard
Massachusetts v. Sheppard is a significant case concerning the Fourth Amendment's protections against unlawful searches and seizures. The case arose after Osborne Sheppard was convicted of first-degree murder, with his conviction later challenged on the grounds that the police executed a search of his residence using a defective warrant. The warrant, originally intended for drug-related searches, was improperly modified to search for evidence related to the murder. The Massachusetts Supreme Judicial Court ruled in favor of Sheppard, stating that the evidence should be excluded due to the warrant's defects and not recognizing a good-faith exception to the exclusionary rule. However, the U.S. Supreme Court later reversed this decision, determining that the police acted in good faith, believing they had a valid warrant. Justice Byron White emphasized that the exclusionary rule aims to deter police misconduct, not to penalize officers for judges' errors. This case underscores the complexities of search warrant validity and the balance between law enforcement practices and individual rights.
Massachusetts v. Sheppard
The Case: U.S. Supreme Court ruling on searches
Date: Decided on July 5, 1984
Significance: The Court ruled that, the Fourth Amendment notwithstanding, a search authorized by a defective warrant was proper because the police had acted in good faith in executing what they thought was a valid warrant.
Osborne Sheppard was convicted in a Massachusetts state court of first-degree murder. Sheppard appealed his conviction to the Massachusetts Supreme Judicial Court on the basis that the police had knowingly searched his residence with a defective search warrant.
Boston police detective Peter O’Malley had drafted an affidavit to support an application for an arrest warrant and a search warrant authorizing the search of Sheppard’s residence. The affidavit stated that the police wanted to search for such items as the victim’s clothing and a blunt instrument that might have been used on the victim. The affidavit was reviewed and approved by the district attorney.
Unable to find a proper warrant application form, O’Malley found a previously used warrant form used in another district to search for controlled substances. After O’Malley made some changes on the form, it and the affidavit were presented to a judge at his residence. The judge was made aware of the defective warrant form, and he made further changes before he signed it. He did not change the substantive portion, however, which continued to authorize a search for controlled substances, nor did the judge alter the form to incorporate the affidavit.
The police believed that the warrant authorized the search, and they proceeded to act in good faith. The trial judge ruled that the exclusionary rule did not apply in this case because the conduct of the officers was objectively reasonable and largely error free. On appeal, Sheppard argued that the evidence obtained pursuant to the defective warrant should have been suppressed. The Supreme Judicial Court of Massachusetts agreed and reversed the lower court’s conviction of Sheppard. The court held that it did not recognize a good-faith exception to the exclusionary rule.
Massachusetts filed a petition for writ of certiorari. Speaking for the U.S. Supreme Court, Justice Byron R. White stated that the police officers who conducted the search should not be punished. They acted in good faith in executing what they reasonably thought was a valid warrant—one that was subsequently determined invalid—issued by a detached and neutral magistrate (United States v. Leon, 1984). The exclusionary rule, White said, did not apply because it was adopted to deter unlawful searches by police, not to punish the errors of judges. He stated that an error of constitutional dimension may have been committed by the judge who did not make the necessary changes, but not the police. Judgment of the Supreme Judicial Court was therefore reversed and remanded for further proceedings consistent with the U.S. Supreme Court’s opinion.
Bibliography
Bloom, Robert M. Searches, Seizures, and Warrants. Westport, Conn.: Praeger, 2003.
LaFave, W. R. Search and Seizure: A Treatise on the Fourth Amendment. 3d ed. St. Paul, Minn.: West Publishing, 1995.
McWhirter, Darien A. Search, Seizure, and Privacy. Phoenix, Ariz.: Oryx Press, 1994.
Wetterer, Charles M. The Fourth Amendment: Search and Seizure. Springfield, N.J.: Enslow, 1998.