State v. Carter

Eugene Carter appeals his conviction of possession of a controlled substance. He contends that the search warrant upon which the police relied to search his person violated the Fourth Amendment requirement of particularity. The warrant authorized the search of "persons at the residence” at issue, but did not name or describe Carter. We reverse.

Facts

After receiving numerous complaints about drug activ ity at an apartment on South L Street in Tacoma, the police sent a confidential informant to the premises to observe. The informant reported seeing residents using and selling rock cocaine and…