State v. Suppah

Under the Hall test, if there is a causal connection between unlawful police conduct and the discovery of evidence, the evidence cannot be admitted unless the State proves that its discovery was independent of, or only tenuously connected to, the illegal stop.

Defendant appealed his conviction for providing false information to a police officer. During a traffic stop, Defendant provided the Deputy with the name of one of his friends instead of his own name. The Deputy learned that the name provided had a suspended license and Defendant was issued a citation for driving while suspended. One month later, Defendant admitted he provided a false name and was charged with giving false information to a police officer. Defendant claimed the stop was unlawful and moved to suppress evidence obtained during the traffic stop. The State agreed the stop was unlawful, but the evidence discovered was attenuated. The trial court denied the motion and Defendant was found guilty. On appeal, Defendant renewed his argument. The Court found the stop unlawful and determined whether the statements obtained during and after the stop were subject to exclusion. Applying the Hall test, the Court held that the statements made during the illegal stop were not attenuated and were not subject to an exception, thus the trial court erred by denying the motion. Although the Court found the statements made a month later attenuated, admission of those statements was not harmless because a conviction could not have been secured solely on those statements. Reversed and remanded.