Sixth Circuit finds violation of 4th Amendment in search pursuant to overly-vague warrant
Lansing Police were investigating a series of home invasions when they focused on a particular apartment complex. Ultimately, after the arrest of one suspect, a warrant issued for the search of an apartment occupied by Stella Wheeler and her boyfriend, Michael Adams. Pursuant to the warrant, police were authorized to seize broad categories of items, and they did. Wheeler claimed that several of the items seized were her personal property and that the warrant, and the affidavit on which it was based, were so vague that they violated the U.S. Constitution. The trial court agreed that the legal documents were unconstitutionally vague but ruled that Dennis Wirth, the officer who conducted the seizure, enjoyed qualified immunity from liability.
The Sixth Circuit re-evaluated Wheeler's 1983 claim on appeal and concluded that a reasonable officer would have recognized that the subject warrant was unconstitutionally vague. On that basis, it reversed the lower court and reinstated the case. It held "it would be apparent to a reasonable officer that listing general categories of items to be seized even though further details are available violates the Fourth Amendment's specificity requirement."