Joanne Blight v. City of Manteca
944 F.3d 1061
9th Cir.2019Background
- September 2014: Manteca detectives Garcia and Osborn received detailed, previously reliable confidential-informant information that Marlin Ford ran an outdoor marijuana grow on a fenced 4.26-acre Stockton property (5858 E. Carpenter Rd) that contained two modular homes.
- Detectives corroborated Ford’s residence via law-enforcement databases and DMV photo, drove the informant to the property, and attached a Google Maps aerial image and an affidavit describing two residences and buildings to a warrant application.
- A state judge issued a warrant; SWAT breached the property in October 2014, forced entry into a mobile home after announcements, and removed 74-year-old Joanne Blight from the trailer and detained her on-scene for the duration of the search (about 20–60 minutes).
- Police seized large quantities of marijuana and drug paraphernalia from the property but recovered no evidence from the mobile home; the mobile home had belonged to the Blights since 1997 and had a separate address (5846 E. Carpenter Rd) though it sat on the 5858 parcel.
- Blight sued under 42 U.S.C. § 1983 alleging Fourth Amendment violations (overbroad warrant, overbroad execution, unlawful detention, and judicial deception by omissions); the district court granted summary judgment for defendants and declined supplemental jurisdiction over state claims.
- The Ninth Circuit affirmed, holding the warrant and its execution were supported by probable cause, the detention was lawful incident to the search, and alleged affidavit omissions were not deliberate/reckless or material.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to search mobile home (overbroad warrant) | Warrant lacked probable cause for Blight's trailer because it was a separate residence and occupants were unrelated to Ford's operation | Informant's detailed, corroborated firsthand information and detective expertise supported a fair probability that evidence would be in both residences on the fenced property | Affirmed: probable cause supported search of entire property including mobile home because Ford controlled the premises and residences were suspect |
| Whether officers should have stopped searching mobile home after learning occupants' identities | Officers were put on notice that the mobile home was separately owned/occupied by the Blights, so continued search was outside warrant scope | New information (who lived where; Ford not present) did not eliminate probable cause or officers' reasonable belief that the property remained under Ford's control | Affirmed: officers reasonably continued search; information did not negate probable cause or control inference |
| Detention incident to search | Detention of 74-year-old Blight without handcuffing, search, or evidence linking her was unreasonable and excessive in duration | Officers had categorical authority to detain occupants during a lawful narcotics search to prevent destruction of evidence; detention was short and nonintrusive | Affirmed: detention reasonable incident to valid search; manner and duration were reasonable |
| Judicial deception by affidavit omissions | Affidavit omitted material facts (leniency promise to informant; Blights living there; Ford's other home; address details) amounting to deliberate or reckless omission that misled judge | Omissions were immaterial or, even if inaccurate, did not show deliberate/reckless conduct and did not destroy probable cause given corroboration and totality of circumstances | Affirmed: no substantial showing of deliberate or reckless omission material to probable cause |
Key Cases Cited
- Kaley v. United States, 571 U.S. 320 (2014) (probable cause is not a high bar)
- Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances fair-probability test for probable cause)
- Muehler v. Mena, 544 U.S. 93 (2005) (officers may detain occupants incident to a lawful search)
- Maryland v. Garrison, 480 U.S. 79 (1987) (officers must stop if put on notice that search exceeds warrant scope)
- United States v. Alexander, 761 F.2d 1294 (9th Cir. 1985) (warrant of entire ranch valid where suspect controls whole premises)
- United States v. Angulo-Lopez, 791 F.2d 1394 (9th Cir. 1986) (courts may draw reasonable inferences about where evidence is likely kept)
- United States v. Whitten, 706 F.2d 1000 (9th Cir. 1983) (separate residences require probable cause for each)
- Ewing v. City of Stockton, 588 F.3d 1218 (9th Cir. 2009) (probable-cause corroboration and summary-judgment review principles)
- In re Grand Jury Subpoenas, 926 F.2d 847 (9th Cir. 1991) (warrant breadth must align with probable cause)
- Chism v. Washington State, 661 F.3d 380 (9th Cir. 2011) (standard for showing deliberate or reckless omission in judicial deception claims)