Garrison, on the other hand, did involve the mistaken execution of a valid warrant on the wrong premises.
Garrison makes clear that the Fourth Amendment's allowance for officers' honest mistakes is limited to mistakes that are objectively reasonable.
480 U.S. at 87 & n. 11, 107 S.Ct. at 1018 & n. 11. The officers in
Garrison obtained a warrant to search a man named McWebb and the “third floor apartment” at a certain address. Unbeknownst to the officers, the named premises contained two apartments on the third floor, one rented by McWebb and one rented by Garrison. The officers searched Garrison's apartment based on the overly broad warrant description. In upholding the search of Garrison's apartment, the Supreme Court observed that if the officers knew or should have known before they entered Garrison's apartment that the warrant incorrectly included it, the officers could not have legally searched it.
Id. at 86, 107 S.Ct. at 1017. The Court stated the validity of the search depended on the objective reasonableness of the officers' failure to realize the warrant's overbreadth.
Id. at 88, 107 S.Ct. at 1018. Because the objective facts available to the officers at the time did not suggest a distinction between McWebb's apartment and the third floor, the officers' mistaken search of Garrison's apartment was objectively reasonable.
Id. Thus, under
Garrison, the execution of a valid warrant on the wrong premises violates the Fourth Amendment if the officers should know the premises searched are not the premises described in the warrant, i.e., the officers' mistake is not objectively reasonable.
Id. at 86–88, 107 S.Ct. at 1017–18; see Samuels v. Smith, 839 F.Supp. 959, 963 (D.Conn.1993).