Utah v. Strieff

Evidence acquired in violation of the Fourth Amendment’s exclusionary rule is admissible when an officer, conducting a good faith, bona fide investigation, discovers a valid warrant against the defendant, which qualifies as an intervening circumstance in application of the attenuation exception to the exclusionary rule.

A narcotics detective observed Respondent leaving a suspected drug house and detained him for questioning. After discovering Respondent had an outstanding warrant, the detective arrested Respondent and found methamphetamine and drug paraphernalia on him. Respondent was charged with possession and moved to suppress evidence arising from the stop. The State stipulated that the officer lacked reasonable suspicion, but the trial court determined that evidence from the stop was admissible. The trial court’s decision was upheld by an intermediate appeals court and subsequently reversed by the Utah Supreme Court. On appeal, the U.S. Supreme Court determined that the attenuation exception to the Fourth Amendment’s exclusionary rule applied. In its application, the Court balanced the three factors set forth in Brown v. Illinois, 422 U. S. 590 (1975): (1) “temporal proximity,” (2) “the presence of intervening circumstances,” and (3) the “purpose and flagrancy of the official misconduct.” The Court held that the short length of time between the illegal stop and the discovery of the warrant weighed in favor of suppressing the evidence. However, the Court determined that the discovery of a valid arrest warrant compels an officer to make a search or arrest, and is a substantial intervening circumstance. The Court further determined that the unlawful stop was made in good faith, and was “at most negligent,” because it occurred during a bona fide investigation of the suspected drug house. Because the proximity of time was outweighed by the superseding discovery of an arrest warrant and the officer’s good faith conduct, the evidence was held admissible. REVERSED.