State v. Browne

The particularity clause of the fourth amendment requires that “no warrants *322shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.” U.S. Const., amend. IV. Because the search and seizure warrant in the present case mistakenly referenced the illicit drug cocaine instead of the illicit drug marijuana, the majority, relying on Groh v. Ramirez, 540 U.S. 551, 124 S. Ct. 1284, 157 L. Ed. 2d 1068 (2004), concludes that the warrant failed to comply with that constitutional mandate. I…