The F ourth Amendment provides that "no W arrants shall issue, but upon probable cause,
supported by Oath or affirmation, and particularly describing the place to be searched, and the
persons or thing s to be seiz ed." U.S. Const. amend. I V (emphasis added). The particularity -ofdescription requirement is satisfied where "the description is such that the officer with a search
warrant can with reasonable effort ascertain and identify the place intended." Steele v. United
States , 267 U.S. 498, 503 (1925). "I n apply ing this requirement to searches aimed at residences
within multi[ -]unit building s, such as the search in the present case, courts have declared invalid
those warrants that fail to describe the targ eted unit with enoug h specificity to prevent a search of
all the units." Maryland v. Garrison , 480 U.S. 79, 90 (1987) (B lackmun, J ., dissenting ). For
example, in Garrison , when officers and the search warrant failed to recog nize that the third floor
of an apartment had two separate apartments, not one, the search was valid only because the
officers reacted to the information learned at the scene and refrained from searching the incorrect
apartment on that floor. Id. at 86-89.
In this case, officers obtained a search warrant for an apartment in a four-unit building .
The affidavit submitted in support asserted that the door to the apartment would be marked with
the letter B on the door. The affidavit referred to unit or apartment "B " 12 times. The warrant
described the unit as being marked with a "B " but on the second floor. Petitioner had never been
seen leaving an apartment on the second floor. He had been seen entering a door on the first floor
and reappearing with drug s. When officers arrived on the scene, the special weapons unit had
busted down a door that was not marked with a "B ." And y et the officers entered and searched
anyway, without looking to see if any other unit was marked with a "B ." Evidence showed that
there was an apartment door on the first floor marked with a "B ." The first question, then, is
whether the state courts errs and rules contrary to this Court's precedent in failing to find that a
warrant fails to describe the place to be searched with sufficient particularity and therefore a hig h
probability existed that the wrong residence would be searched.

An invalid warrant does not lead to suppression if the officers reasonably believe the
search warrant was valid. United States v. Leon , 468 U.S. 897, 922-23 (1984). I n this case, by
finding that the search was authoriz ed, the state courts did not reach the question of whether the
Leon good faith ex ception applied. B ecause the Court should accept this case for review and find
that the search was invalid, Leon would become relevant. The officer that investig ated the case
and crafted the affidavit leading to the search warrant was on the scene of the ex ecution of that
warrant. He was the officer that was told by confidential informants that the apartment to be
searched would be marked with a "B " on the door. He could not have reasonably believed that
the warrant was valid when he reached the scene and discovered that the door of the apartment to
be searched was not marked B , especially when evidence introduced in the case showed that
another apartment was marked with a B and the officer admitted that

Question not identified.