State v. Gruntz

To determine whether the affidavit in support of a search warrant is sufficient, the state applies the reasoning of State v. Castilleja. That is, the court’s function is limited in scope to determining whether a magistrate could have reasonably concluded the facts in an affidavit established probable cause for a search warrant.

The state appealed the trial court’s order suppressing evidence of animal neglect. The trial court determined an affidavit supporting two search warrants was insufficient and did not establish probable cause regarding animal neglect. The state posits that the trial court’s analysis was not congruent with State v. Castilleja because the trial court made its own findings, rather than determining whether an issuing magistrate could reasonably find probable cause. In Castilleja, the Court held that when a defendant sought to suppress evidence, the court’s function was limited in scope to determining whether the magistrate could reasonably conclude the facts of the affidavit established probable cause for a search warrant. In this case, the affidavit established the horses suffered from malnutrition and needed more consistent feeding. Additionally, the sheriff’s office received complaints from eight citizens and the ranch manager stating the horses were not regularly fed. Using these facts, a magistrate could have determined the affidavit established probable cause and a search of the ranch would result in evidence of animal neglect. Reversed and remanded.