Utah v. Strieff
Supreme Court of the United States
February 22, 2016, Argued; June 20, 2016, Decided
JUSTICE Thomas delivered the opinion of the Court.
To enforce the Fourth Amendment’s prohibition against “unreasonable searches and seizures,” this Court has at times required courts to exclude evidence obtained by unconstitutional police conduct. But the Court has also held that, even when there is a Fourth Amendment violation, this exclusionary rule does not apply when the costs of exclusion outweigh its deterrent benefits. In some cases, for example, the link between the unconstitutional conduct and the discovery of the evidence is too attenuated to justify suppression. The question in this case is whether this attenuation doctrine applies when an officer makes an unconstitutional investigatory stop; learns during that stop that the suspect is subject to a valid arrest warrant; and proceeds to arrest the suspect and seize incriminating evidence during a search incident to that arrest. We hold that the evidence the officer seized as part of the search incident to arrest is admissible because the officer’s discovery of the arrest warrant attenuated the connection between the unlawful [***6] stop and the evidence seized incident to arrest.
This case began with an anonymous tip. In December 2006, someone called the South Salt Lake City police’s drug-tip line to report “narcotics activity” at a particular residence. App. 15. Narcotics detective Douglas Fackrell investigated the tip. Over the course of about a week, Officer Fackrell conducted intermittent surveillance of the home. He observed visitors who left a few minutes after arriving at the house. These visits were sufficiently frequent to raise his suspicion that the occupants were dealing drugs.
[*2060] One of those visitors was respondent Edward Strieff. Officer Fackrell observed Strieff exit the house and walk toward a nearby convenience store. In the store’s parking lot, Officer Fackrell detained Strieff, identified himself, and asked Strieff what he was doing at the residence.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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136 S. Ct. 2056 *; 195 L. Ed. 2d 400 **; 2016 U.S. LEXIS 3926 ***; 84 U.S.L.W. 4430; 26 Fla. L. Weekly Fed. S 288
UTAH, Petitioner v. EDWARD JOSEPH STRIEFF, JR.
Notice: The LEXIS pagination of this document is subject to change pending release of the final published version.
Prior History: [***1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF UTAH
State v. Strieff, 2015 UT 2, 357 P.3d 532, 2015 Utah LEXIS 4 (2015)
Disposition: 2015 UT 2, 357 P. 3d 532, reversed.
arrest, suppression, discovery, attenuation, discovery of evidence, drugs, stops, intervening circumstance, traffic, outstanding warrant, exclusionary rule, police misconduct, seizure, courts, reasonable suspicion, warrant check, confession, misconduct, factors, incident to arrest, the Fourth Amendment, exploiting, apartment, deterrent, suspected, flagrant, warrants, Rights, online, seized
Constitutional Law, Fundamental Rights, Search & Seizure, Exclusionary Rule, Criminal Law & Procedure, Fruit of the Poisonous Tree, Attenuation, Exclusionary Rule, Rule Application & Interpretation, Scope of Protection, Exceptions to Exclusionary Rule, Independent Source Doctrine, Inevitable Discovery, Warrants, Search Warrants, Commencement of Criminal Proceedings, Arrests, Seizure of Persons