State v. King

FINE, J.

¶ 33. (dissenting). I respectfully dissent because in my view the Majority ignores both the deference to which we owe the warrant-issuing magistrate, see State v. Sloan, 2007 WI App 146, ¶ 8, 303 Wis. 2d 438, 446, 736 N.W.2d 189, 193, and also the commonsense standard we must apply in assessing on appeal a warrant's validity, see Illinois v. Gates, 462 U.S. 213, 230-231, 238, 240 (1983) (We must consider the "totality of the circumstances" as revealed by the affidavit and the "reasonable inferences" that permit the issuing magistrate "to make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit... there is a fair probability that contraband or evidence of a crime will be found in a particular place."). I address briefly the three legs of the Majority's stool.

A. Alleged Staleness.1

¶ 34. The extensive affidavit in support of the search warrant issued in this case was designed to gather evidence of a large, continuing drug-delivery conspiracy. Drug conspiracies are not Mayflies, popping the surface of law-enforcement awareness and dying in *696a day; they last until law enforcement shuts them down. Thus, common sense tells us that drug conspiracies require application of "staleness" principles that might not apply under other circumstances. See United States v. Pruneda, 518 F.3d 597, 604 (8th Cir. 2008) (In light of a "suggested . . . ongoing drug conspiracy," information in support of search warrant that was collected over several months was not stale.); United States v. Reyes, 798 F.2d 380, 382 (10th Cir. 1986) (In light of alleged on-going conspiracy, five-month lapse did not make information in support of warrant "imper-missibly stale."). United States v. Smith, 266 F.3d 902, 904-905 (8th Cir. 2001) (three-month lapse), states the universally accepted rule:

There is no fixed formula for determining when information has become stale. The timeliness of the information supplied in an affidavit depends on the circumstances of the case, including the nature of the crime under investigation. "In investigations of ongoing narcotic operations, 'intervals of weeks or months between the last described act and the application for a warrant [does] not necessarily make the information stale.'"

(Citations and quoted source omitted.) The Majority makes new law by ignoring this common-sense reality.

¶ 35. Further, the information given to the magistrate was not stale. As the State points out, the affidavit in support of the search warrant references "other intercepted phone calls within 5 days of the issuance of the search warrant." This indicated that the drug-delivery conspiracy in which King was alleged to be involved was ongoing, and the magistrate could reasonably conclude that the conspiracy was contemporaneous with the issuance of the search warrant. Thus, as part of the alleged conspiracy, the more recent phone-intercepts count in assessing probable cause to *697search King's residence. Cf. Wis. Stat. Rule 908.01(4)(b)5 ("A statement by a coconspirator of a party during the course and in furtherance of the conspiracy" is an "admission" chargeable to other parties to the conspiracy and is thus not hearsay as to them.).

B. & C. Anticipatory Warrant and Particularity.

¶ 36. Although the Majority separates the warrant's listing of a three-unit townhouse under both whether the warrant was sufficiently particular and also whether the anticipatory restriction was valid, the two matters are, in my view, on the same side of the same coin. Thus, I discuss them together.

¶ 37. According to the lengthy affidavit in support of the search warrant, the three-unit townhouse had the address of "8811, 8813, 8815 West Mitchell, West Allis, Wisconsin." As the Majority recounts, however, the affidavit indicated that King lived in but one of the units. Thus, in order to protect the occupants of the other units, the warrant was issued only for the unit occupied by King, and the officers were to knock (which, of course, they are permitted to do) to see who might answer the door. If King answered the door, then the warrant's permission to search that unit would kick-in. I am puzzled by the Majority's condemnation of this protection for the occupants of the other units, and its ruling that the officers should have done more to narrow-down the specific address of King's unit. In my view, this imposes unnecessary hurdles; the warrant was issued only for King's unit, once they lawfully (by knocking) ascertained it. If no one answered the door, or King could not be seen from outside the door's threshold, the warrant did not authorize the officers' *698entry and search (unless the person opening the door allowed the officers to come in and they saw King once they were inside).

¶ 38. In essence, I believe that the Majority and the parties misstate the issue by focusing on the concept of "anticipatory warrant," which, as the Majority correctly notes, generally accommodates the need to interdict contraband that may be in transit. This appeal, as I see it however, merely deals with a warrant that authorizes law enforcement to enter one of three connected residences once law enforcement ascertained the one in which King lived.

¶ 39. In my view, the Majority has crimped the law. I would affirm and, accordingly, I respectfully dissent.