U.S. Supreme Ct - June 20, 2016

by: Aalvarez • June 20, 2016 • no comments

Under the Fourth Amendment, evidence discovered during an illegal stop does not necessarily qualify for suppression when the defendant is searched after officers learn he has an outstanding arrest warrant. Here, a narcotics detective conducted surveillance on a home based on an anonymous tip about drug activity. He observed people frequently visiting the home and that made him suspicious that the occupants were dealing drugs. After watching a man leave the home, later identified as the defendant, the detective detained the defendant and asked him what he was doing at the home. He then requested the defendant's identification and relayed the information to dispatch, who informed him that the defendant had an outstanding arrest warrant. The officer arrested and searched the defendant, eventually locating methamphetamine and drug paraphernalia. The defendant moved to suppress the evidence, arguing that it was the result of an unlawful stop.

The U.S. Supreme Court ruled that the evidence was admissible because, based on the attenuation factors expounded in Brown v. Illinois, there was no flagrant police misconduct. Although the temporal proximity between the initial unlawful stop and the search favors suppression of the evidence, the second factor, "the presence of intervening circumstances," strongly favored the state. The existence of a valid warrant was completely independent and entirely unconnected with the stop. Moreover, the warrant authorized the officer to arrest the defendant and once the arrest was authorized, his search incident to that arrest was lawful. Lastly, the third factor, "the purpose and flagrancy of the official misconduct" also favored the state, because according to the U.S. Supreme Court, the officer was at most negligent and his errors in judgment do not rise to a purposeful or flagrant violation of the defendant's Fourth Amendment rights. After the stop, his conduct was lawful, and there was no indication that the stop was part of any systemic misconduct.