United States v. Grubbs, 547 U.S. 90 (2006)
Primary Holding
An anticipatory search warrant is valid under the Fourth Amendment if it is supported by probable cause and describes the triggering condition that must occur before the warrant is executed, but it is not required to include the triggering condition in the warrant itself.
In the case of United States v. Grubbs, law enforcement obtained a special type of search warrant that allowed them to search Grubbs' home only after a package containing illegal material was delivered there. This matters because it shows that police can use anticipatory warrants—warrants that are valid as long as they are based on good reason and describe what has to happen before they can be used. For consumers, this case helps clarify that police can act quickly and effectively to prevent illegal activities, but it also reinforces the importance of having clear rules about when and how searches can happen. This case is relevant if someone is facing a search of their home and wants to know if the warrant was properly issued and whether their rights were respected.
AI-generated plain-language summary to help you understand this case
In United States v. Grubbs, 547 U.S. 90 (2006), the underlying events began when Jeffrey Grubbs purchased a videotape containing child pornography from a website operated by an undercover postal inspector. Federal law enforcement officers, specifically from the Postal Inspection Service, arranged for a controlled delivery of the package containing the videotape to Grubbs' residence. A search warrant was obtained from a Magistrate Judge in the Eastern District of California, which included an affidavit detailing that the warrant would only be executed after the package was received and taken into the residence. The warrant was issued, and two days later, the package was delivered to Grubbs' wife, who signed for it and brought it inside. Shortly after, Grubbs was detained as he left his home, and the search commenced. Procedurally, after the search, Grubbs was indicted by a grand jury for receiving a visual depiction of a minor engaged in sexually explicit conduct. He moved to suppress the evidence obtained during the search, arguing that the warrant was invalid because it did not explicitly list the triggering condition for its execution. The District Court denied his motion to suppress, and Grubbs subsequently pleaded guilty while reserving the right to appeal the denial. The case was then taken to the Court of Appeals for the Ninth Circuit, which reversed the District Court's decision, stating that the particularity requirement of the Fourth Amendment applies to the conditions precedent of an anticipatory search warrant. The relevant background context includes the legal framework surrounding anticipatory search warrants, which are designed to allow law enforcement to execute a search based on a future event, such as the delivery of contraband. The Ninth Circuit's ruling emphasized the importance of specificity in warrants, particularly concerning the conditions that must be met before a search can be conducted. This case ultimately raised significant questions about the constitutionality and requirements of anticipatory warrants under the Fourth Amendment.
Whether the particularity requirement of the Fourth Amendment applies to the conditions precedent for an anticipatory search warrant.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- January 18, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Scalia
- Damages Awarded
- N/A
- Data Quality
- high
Hudson v. Michigan, 547 US 586 (2006)
Consumer LostThe violation of the "knock-and-announce" rule does not require the suppression of evidence obtained during a search conducted pursuant to a valid warrant.
Samson v. California, 547 U.S. 843 (2006)
Consumer LostA suspicionless search of a parolee conducted under California law does not violate the Fourth Amendment, as the conditions of parole significantly diminish the parolee's reasonable expectation of privacy.
Georgia v. Randolph, 547 U.S. 103 (2006)
Consumer WonA warrantless search of shared premises is unreasonable and invalid if one co-occupant is present and expressly refuses consent, even if another co-occupant provides consent for the search.
Shepard v. United States, 544 U.S. 13 (2005)
Consumer LostA sentencing court under the Armed Career Criminal Act (ACCA) may not consider police reports or complaint applications to determine whether a prior guilty plea necessarily admitted to generic burglary; it is generally limited to examining the statutory definition, charging document, written plea agreement, transcript of plea colloquy, and any explicit factual finding by the trial judge to which the defendant assented.