Massachusetts v. Sheppard Case Brief

Massachusetts v. Sheppard, 468 U.S. 981, 104 S.Ct. 3424 (1984)

FACTS: On May 5, 1979, the badly burned body of Sandra Boulware was found in a vacant lot in Boston. An autopsy showed that she had died from multiple skull fractures caused by blows. Investigation led to a boyfriend, Osborne Sheppard. Sheppard’s alibi fell through, when it was discovered that he was absent from the location where he claimed to be for several hours, sufficient to commit the crime, and that he had borrowed a vehicle during that time.

The police visited the owner of the car and received permission to search it. Blood and hair were found on the rear bumper and in the trunk, and wire in the trunk was similar to wire found on and near the body. The owner had used the car just previous to when Sheppard borrowed it, and had not noticed any stains.

Det. O’Malley drafted a search warrant, but had a difficult time finding the form normally used for search warrant. He found a form warrant for Controlled Substances, for another area, but deleted the portions that did not apply and substituted the correct information on the form. However, he neglected to delete other, non-applicable, statements on the form. He took the form to a local judge, who made the changes he believed necessary to create a valid warrant, but also neglected to delete several relevant portions. They found several incriminating items, not specifically listed on the warrant but described in the accompanying affidavit, and the search had been consistent with the scope allowed by the warrant. However, the judge had neglected to attach or otherwise reference the affidavit in the actual warrant form. Sheppard was indicted for murder.

The trial court denied Sheppard’s request for suppression. While admitting the form of the warrant was somewhat defective, that the officers acted in good faith in executing what they believed to be a valid warrant. The Massachusetts Supreme Court, however, agreed with Sheppard and suppressed the evidence, because Massachusetts had not yet recognized a good-faith exception to the Exclusionary Rule.

ISSUE: Is an officer justified in relying on what is later found to be an invalid warrant?

HOLDING: Yes

DISCUSSION: The Court found that “[I]f an officer is required to accept at face value the judge’s conclusion that a warrant form is invalid, there is little reason why he should be expected to disregard assurances that everything is all right, especially when he has alerted the judge to the potential problems.” If anyone made a mistake in the situation, it was not the officers but the judge. The Exclusionary Rule was adopted to prevent the police from doing unlawful searches, not to control the actions of judges. Suppressing evidence when the judge makes the errors, not the police, does not serve the purpose of the Exclusionary Rule.