Groh v. Ramirez

An ATF agent (Groh) applied for a search warrant to search the Defendant (Ramirez)’s ranch for weapons, but did not include the items to be sought in the warrant. The warrant was subsequently issued by a federal magistrate judge. Nothing was found, and no charges were filed against Ramirez. Later, Ramirez sued Groh for violating his Fourth Amendment rights on the basis that the warrant was plainly invalid because Groh failed to include the particular items that were meant to be searched pursuant to the warrant and instead described Ramirez’s house. In Groh’s defense, the application and accompanying affidavit for the warrant did in fact accurately describe the items to be sought, and the Magistrate who approved the warrant did so because of sufficient probable cause. The District Court held that Groh retained “qualified immunity” so long as he didn’t violate a “clearly established constitutional right” in conducting his duties. The Appeals Court reversed, finding no immunity because Groh was personally responsible for the use of the warrant.