Introduction

This summary order addresses two recurring Fourth Amendment questions that arise in warrant practice and civil rights litigation under 42 U.S.C. § 1983: (1) when an officer may obtain and execute a warrant for an entire residence at a single street address that actually contains more than one apartment, and (2) whether—and for how long—officers may remain in a particular unit once they receive information on scene that the target of the warrant resides elsewhere in the same structure.

The plaintiffs—Caridad Medina (individually and as parent and natural guardian of A.S. and B.S.), Douglass Smalls, and Briana Spencer—sued Detective Brian Stevens, alleging that he violated their Fourth Amendment rights when he secured and executed a warrant for the entire premises at 38 Clifford Court without distinguishing between Apartment 38A and Apartment 38B. They also challenged his remaining in Apartment 38B for approximately 10–15 minutes after being told that the suspected drug dealer, Jimmy Betts, lived downstairs.

The district court granted summary judgment for Detective Stevens. On appeal, the Second Circuit affirmed, holding that (i) the issuing judge had a substantial basis to find probable cause for a search of the entire premises, and (ii) the brief continued presence in Apartment 38B was reasonable under the circumstances.

Summary of the Opinion

• Probable Cause and the Warrant’s Scope: The court emphasized the deferential “substantial basis” review of a magistrate’s probable cause determination and the presumption of reasonableness accorded to searches conducted pursuant to a warrant. Plaintiffs failed to make the “substantial preliminary showing” required by Franks v. Delaware and its Second Circuit progeny to invalidate the warrant based on alleged misstatements or omissions. Observations of hand-to-hand transactions by a man exiting and re-entering 38 Clifford Court through the front door (which led to Apartment 38B) and the absence of knowledge about the internal configuration and access between units supported probable cause to search the entire address.
• Duration of Presence: Remaining in Apartment 38B for about 10–15 minutes after being told Betts lived downstairs was reasonable because the warrant was supported by probable cause as to the entire premises and the officer did not know whether the units were interconnected or accessible to the suspect.
• Outcome: Summary judgment for Detective Stevens affirmed.

Detailed Analysis

1) Precedents and Authorities Cited

• Sista v. CDC Ixis N. Am., Inc., 445 F.3d 161 (2d Cir. 2006)
  The panel reiterates the de novo standard for reviewing summary judgment, with all reasonable inferences drawn in favor of the non-movant, and the Rule 56(a) requirement that no genuine dispute of material fact exists.
• United States v. Raymonda, 780 F.3d 105 (2d Cir. 2015)
  Articulates the probable cause standard for warrants: a “practical, common-sense” determination that there is a fair probability that evidence will be found in a particular place. Also underscores the substantial deference owed to the issuing judicial officer.
• Walczyk v. Rio, 496 F.3d 139 (2d Cir. 2007)
  Establishes that searches conducted pursuant to a warrant issued by a neutral magistrate are presumed reasonable. Appellate review focuses on whether the magistrate had a “substantial basis” for the probable-cause determination.
• Franks v. Delaware, 438 U.S. 154 (1978); Golino v. City of New Haven, 950 F.2d 864 (2d Cir. 1991)
  Provide the framework for challenging a warrant affidavit. A plaintiff must make a substantial preliminary showing that the affiant knowingly or recklessly included false statements or omitted material facts, and that such misstatements/omissions were necessary to the finding of probable cause.
• United States v. Rajaratnam, 719 F.3d 139 (2d Cir. 2013)
  Clarifies that omissions must be “designed to mislead” or made with reckless disregard for whether they would mislead. Negligence or innocent mistakes are insufficient.
• Velardi v. Walsh, 40 F.3d 569 (2d Cir. 1994) (n.3)
  Confirms that negligence does not equate to reckless disregard for purposes of a Franks challenge.
• Panetta v. Crowley, 460 F.3d 388 (2d Cir. 2006)
  Officers with a reasonable basis for probable cause are not required to explore and eliminate every theoretically plausible innocent explanation before taking action.
• United States v. Silva, 146 F.4th 183 (2d Cir. 2025)
  Reaffirms that probable cause requires a sufficient nexus between criminal activity and the place to be searched. The court employs this “nexus” concept to sustain the warrant covering 38 Clifford Court as a whole.

Although not cited by the panel, the Supreme Court’s decision in Maryland v. Garrison, 480 U.S. 79 (1987), provides broader doctrinal context for the reasonableness of searches where officers reasonably but mistakenly believe a location is a single unit when it is in fact subdivided. Medina aligns with Garrison’s core premise: the Fourth Amendment’s touchstone is reasonableness, assessed in light of what the officers knew (or reasonably should have known) at the time.

2) The Court’s Legal Reasoning

a) Presumption of Reasonableness and Deferential Review of the Warrant

The court begins from two entrenched principles. First, searches pursuant to warrants issued by neutral magistrates are presumed reasonable. Second, appellate review asks only whether the issuing judge had a “substantial basis” for the probable-cause determination. Against that backdrop, plaintiffs bore a heavy burden to overcome the presumption, namely a Franks/Golino showing of intentional or reckless falsehoods or omissions that were material to the finding of probable cause.

b) The “Nexus” and the Undifferentiated Multi-Unit Premises

On the record described, Detective Stevens’s affidavit tied suspected narcotics activity to 38 Clifford Court in two principal ways: law enforcement observed an individual twice exit the residence to conduct a hand-to-hand transaction and then re-enter “through the front door,” which, factually, was the entrance to Apartment 38B; and Stevens stated he did not know whether the suspect (Betts) lived in either unit, whether he had access to both units, or whether the apartments were interconnected. In short, the officers had indicia that the criminal activity was associated with the address and point of entry used by occupants of 38B, but lacked reliable information separating the spaces or confining the contraband to one unit.

That uncertainty mattered. Under Panetta, officers are not required to dispel every alternative hypothesis before acting. And under Silva, the question is whether there is a sufficient nexus between the crime and the place to be searched—here, the structure at 38 Clifford Court, as described in the warrant. The panel concluded there was such a nexus for “the entirety of 38 Clifford Court.” The absence of evidence that Stevens knew drugs were stored in only one unit, combined with observations tied to the front door used by Apartment 38B and uncertainty about access between units, gave the issuing judge a substantial basis to authorize a search of the whole premises at that address.

Plaintiffs argued the affidavit was “littered” with material misstatements/omissions—chiefly, that it failed to differentiate between 38A and 38B while implying the entire premises were used for drug dealing. The court rejected this characterization. There was no evidence that Stevens “intentionally lied, purposefully withheld, or recklessly omitted” facts. At most, the record reflected uncertainty (e.g., not knowing Betts’s apartment, the connectivity of the units, or who had access where). Under Franks, Rajaratnam, and Velardi, negligence, uncertainty, or innocent mistakes do not suffice. Because the alleged deficiencies were neither intentional nor reckless and were not shown to be material to the probable cause determination, the Franks challenge failed.

d) Continued Presence for 10–15 Minutes

After entry, Medina reportedly told officers that Betts lived in the downstairs apartment. Plaintiffs argued that Stevens’s remaining for roughly 10–15 minutes in 38B violated the Fourth Amendment. The court disagreed. Given that the warrant covered the entire premises and that Stevens did not know whether Betts could access both units or whether the apartments were interconnected, a brief period of continued presence to complete the investigation was reasonable. The court did not announce a bright-line rule; rather, applying the totality-of-circumstances reasonableness standard, it held that 10–15 minutes was not excessive here.

3) Impact and Forward-Looking Implications

Practical impact for law enforcement and warrant drafting

• Multi-unit uncertainty does not doom a warrant where officers have probable cause tied to the address and a reasonable basis to believe contraband or evidence may be found somewhere within the structure, especially where entrances or observations tie activity to a shared or ambiguous point of access.
• Document the uncertainty. The order implicitly rewards forthright disclosure of investigative unknowns (e.g., whether units are separate, interconnected, or accessible to the suspect). Transparency helps defeat a Franks claim and sustains a magistrate’s probable cause finding.
• Particularity remains vital. If officers have reliable information pinpointing a specific unit, the warrant should be tailored accordingly. This order does not license overbroad warrants; it upholds a whole-premises warrant where the facts reasonably supported it.

Litigation consequences in § 1983 suits

• High bar for Franks-based civil liability. Plaintiffs must marshal evidence of intentional or reckless falsehoods/omissions that are material, not mere negligence or investigative ambiguity.
• Post-entry adjustments matter but are fact-specific. Short, reasonable continuation of a search within the scope of a valid warrant—even after receiving new on-scene information—may be constitutionally permissible where access and connectivity remain unresolved.

Limitations and caveats

• Nonprecedential status. As a summary order, Medina provides persuasive guidance but does not bind future Second Circuit panels.
• Facts matter. A different outcome could follow if officers had definitive pre-warrant knowledge of separate units, if the affidavit omitted crucial segregating facts, or if the continued presence after clarifying information were prolonged or unjustified.

Complex Concepts Simplified

• Probable Cause (Warrants): A practical, common-sense judgment that there is a fair probability that evidence of a crime will be found in the place to be searched.
• “Substantial Basis” Review: Appellate courts defer to the magistrate who issued the warrant, asking only whether there was a substantial basis for concluding probable cause existed.
• Franks Challenge: To invalidate a warrant, a plaintiff must show (1) the affiant knowingly or recklessly included falsehoods or omitted key facts, and (2) those were necessary to the magistrate’s finding of probable cause. Innocent or negligent errors are not enough.
• Nexus Requirement: There must be a connection between the suspected criminal activity and the place to be searched.
• Multi-Unit Particularity: When a building has multiple apartments, warrants should typically identify the specific unit. However, where officers reasonably believe the premises function as one unit or cannot determine unit boundaries or access, a whole-premises warrant can be reasonable.
• Reasonableness of Continued Presence: Even after learning new information on scene, officers may reasonably remain briefly to complete their investigation if the warrant’s scope and the facts (e.g., possible interconnection or access) justify it.
• Summary Judgment: A procedural device to resolve a case without trial when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law.

Conclusion

Medina v. Stevens reaffirms two central Fourth Amendment principles in the context of multi-unit residences. First, a warrant authorizing a search of an entire premises can rest on probable cause tied to the address where officers reasonably lack clarity about unit boundaries, access, or interconnection—particularly where observations link criminal activity to a primary entrance and there is no evidence of intentional or reckless misrepresentation in the supporting affidavit. Second, a brief continued presence in a particular unit after receiving new information that the target resides elsewhere can be reasonable where the warrant’s scope and unresolved access issues justify finishing the investigation.

For practitioners, the case underscores the value of candidly documenting investigative uncertainties, building a clear “nexus” in the affidavit, and adjusting on scene without precipitously curtailing a warranted search where reasonable questions remain. For litigants, it highlights the demanding standards for overcoming the presumption of reasonableness accorded to magistrate-approved warrants and the stringent showing required by Franks. Although nonprecedential, Medina supplies persuasive, fact-sensitive guidance on how courts are likely to assess similar disputes at the intersection of probable cause, particularity in multi-unit settings, and the reasonableness of execution.