Blight v. City of Manteca, No. 17-17334 (9th Cir. 2019)
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The Ninth Circuit affirmed the district court's grant of summary judgment to the city and police department officials in an action brought by plaintiff, who was 74 years old at the time, challenging the issuance and execution of a search warrant on her home, as well as her detention incident to the search. In this case, officers acted pursuant to a search warrant to investigate an illegal marijuana operation.
The panel held that there was probable cause to search plaintiff's mobile home based on the informant's reliability and the probability that probative evidence or contraband would be found in the residences on the property, including the mobile home. Therefore, the search warrant's breadth was co-extensive with the scope of the probable cause and was not overbroad. The panel also held that the officers acted reasonably when they continued to search plaintiff's mobile home because the probable cause to search the mobile home did not depend on the suspect living there. Rather, the panel held that the officers had probable cause to continue the search because they could still reasonably believe that the entire property was suspect and that the property was still under the suspect's common control. Furthermore, the panel held that the duration of the detention, about an hour, was reasonable. Finally, none of plaintiff's alleged omissions amounted to judicial deception.
Court Description: Civil Rights. The panel affirmed the district court’s summary judgment in favor of the City of Manteca and Manteca Police Department officials in an action challenging the issuance and execution of a search warrant on plaintiff’s home and her detention incident to the search as unconstitutional under the Fourth Amendment. Plaintiff alleged that the search warrant to investigate an illegal marijuana operation was overbroad because there was no probable cause to search her mobile home, which was separate from the suspect’s main house and had a separate address. The panel held that based on an informant’s reliability and the probability that probative evidence or contraband would be found in the residences on the property, there was probable cause to issue a warrant authorizing a search of the entire property, including the mobile home. Because the search warrant’s breadth was co-extensive with the scope of this probable cause, the warrant was not overbroad. The panel held that the officers acted reasonably when they continued to search plaintiff’s mobile home once they discovered that the named suspect did not live in the home. The panel held that the probable cause to search the mobile home did not depend on any suspect living there. Instead, the officers had probable cause to continue the search BLIGHT V. CITY OF MANTECA 3 because they could still reasonably believe that the entire property was under the suspect’s common control, regardless of whether he was on the property at the time of the search, and regardless of who was found in the mobile home. The panel rejected plaintiff’s contention that the duration of the search was unreasonable under the Fourth Amendment because of her age (74), the lack of evidence linking her to the marijuana operation, and the length of time of the detention. The panel held that given that the officers had a warrant to search the mobile home, they had categorical authority to detain plaintiff, the occupant of the mobile home at the time of the search. The officers also did not detain plaintiff in an unreasonable manner and her detention of no more than one hour was not an unreasonable length of time given the circumstances. Finally, the panel rejected plaintiff’s contention that the search warrant was tainted by judicial deception. The panel held that none of the alleged omissions in the supporting affidavit were material to the issuing judge’s probable cause determination.
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