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In Giordenello v. United States (1957), the U.S Supreme Court ruled that an arrest warrant for petitioner, Joseph Giordenello, was invalid because it did not provide sufficient evidence to support probable cause as required by the Fourth Amendment. The case began when Giordenello was arrested and charged with violating federal narcotics laws based on a complaint filed by a federal agent who had no personal knowledge of the alleged offenses but relied solely on information given to him by other agents. In its decision, the court held that this type of hearsay evidence could not be used as sole justification for issuing an arrest warrant without additional supporting facts or circumstances presented under oath before a magistrate judge. This ruling reinforced protections against unreasonable searches and seizures provided in the Constitution.
In the dissenting opinion for Giordenello v. United States, Justice Tom C. Clark disagreed with the majority's decision to overturn Giordenello's conviction on grounds of an insufficiently supported complaint used to obtain a warrant for his arrest. He argued that the majority had misinterpreted Rule 4 of Federal Rules of Criminal Procedure which governs issuance of warrants and summonses in federal criminal cases. According to him, this rule does not require complaints supporting warrants or summonses to be based on personal knowledge as long as they are made under oath and establish probable cause for belief in defendant’s guilt. In addition, he pointed out that there was no evidence suggesting perjury or bad faith by complainant officer who swore out complaint against Giordanello based on information from other officers involved in narcotics investigation leading up to his arrest.