United States v. Grubbs
United States Supreme Court
547 U.S. 90 (2006)
A postal inspector ran an undercover sting website targeting child pornography purchasers, and Jeffrey Grubbs (defendant) ordered a video. The inspector obtained a search warrant conditioned on someone at Grubbs's residence accepting delivery of the package, with attachments describing Grubbs's home and the anticipated evidence, but the affidavit describing the delivery-based trigger itself was never attached to the warrant. After the package was delivered, inspectors searched Grubbs's home and served him the warrant partway through. Grubbs moved to suppress the evidence, arguing the warrant was invalid because it lacked the affidavit describing its triggering conditions; the appellate court agreed, and the government sought Supreme Court review.
Whether the Fourth Amendment requires that the conditions triggering execution of an anticipatory warrant be set forth in the warrant itself.