Messerschmidt v. Millender

The Court found that “[W]here the alleged Fourth Amendment violation involves a search or seizure pursuant to a warrant, the fact that a neutral magistrate has issued a warrant is the clearest indication that the officers acted in an objectively reasonable manner or, as we have sometimes put it, in ‘objective good faith.’”

Under the circumstances of this case “it would not have been unreasonable for an officer to conclude that there was a ‘fair probability’ that the sawed-off shotgun was not the only firearm [the defendant] owned” or that the “sawed-off shotgun was illegal.” The Court noted that “[E]vidence of one crime is not always evidence of several, but given [the defendant’s] possession of one illegal gun, his gang membership, his willingness to use the gun to kill someone, and his concern about the police, a reasonable officer could conclude that there would be additional illegal guns among others that [the defendant] owned.” The Court expressed similar reasoning for finding the inclusion of the gang-related material in the search warrant as reasonable. Therefore, the officer was entitled to rely on the issuing judge’s finding of probable cause.