Arizona v. Evans

Supreme Court of the United States · 1995 · Criminal Law

Criminal LawFourth AmendmentExclusionary RuleFourth Amendmentexclusionary rulegood-faith exceptionclerical errorcourt employees

Facts

A Phoenix police officer stopped Evans for driving the wrong way on a one-way street and learned through a patrol-car computer that Evans' license was suspended and that there was an outstanding misdemeanor arrest warrant. The officer arrested Evans based on the reported warrant, and during the arrest Evans dropped a hand-rolled cigarette smelling of marijuana; officers then searched his car and found a bag of marijuana. The warrant, however, had been quashed 17 days earlier. At the suppression hearing, court and sheriff's office employees testified that standard procedure required court clerks to notify the sheriff's office when a warrant was quashed, but there was no record that such notice had been given or received.

Issue

Whether the exclusionary rule requires suppression of evidence seized incident to an arrest made in objectively reasonable reliance on a computer record showing an outstanding warrant when that record was erroneous because of a clerical error by court employees. The Court also considered whether it had jurisdiction because the state court decision allegedly rested on an adequate and independent state ground.

Rule

Under the Leon framework, the exclusionary rule applies only where its remedial objective of deterrence is appreciably served. Evidence need not be suppressed when an officer acts in objectively reasonable reliance on an erroneous computer record caused by clerical error of court employees, because exclusion would not significantly deter either court personnel or the arresting officer. Under Michigan v. Long, the Supreme Court has jurisdiction when a state-court decision fairly appears to rest primarily on federal law and no plain statement shows an independent state-law ground.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, Officer Lena Ortiz stopped Devin Marsh for a broken taillight. A courthouse database showed an active bench warrant, so Ortiz arrested him and found cocaine in his jacket pocket during a search incident to arrest. The warrant had actually been recalled two weeks earlier, but a municipal court clerk never transmitted the recall to the database unit.

If Devin moves to suppress the cocaine, how should the court rule under the governing doctrine?

Explanation. The majority held that the exclusionary rule is a remedial device applied only when it will yield appreciable deterrence. When the erroneous warrant record is attributable to court employees rather than police, suppression is not warranted because court clerks are not part of the law-enforcement team and exclusion is unlikely to significantly deter their clerical errors. The arresting officer's objectively reasonable reliance on the database also means suppression would not meaningfully affect her future conduct.