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Utah v. Strieff

Supreme Court of the United States

February 22, 2016, Argued; June 20, 2016, Decided

No. 14-1373

Case Summary

Overview

HOLDINGS: [1]-Where an officer made an unconstitutional investigatory stop, learned during the stop that the suspect was subject to a valid arrest warrant, arrested the suspect, and seized incriminating evidence during a search incident to that arrest, the evidence the officer seized as part of the search incident to the arrest was admissible under the Fourth Amendment because the officer's discovery of the arrest warrant attenuated the connection between the unlawful stop and the evidence seized incident to arrest; [2]-The logic of the Supreme Court's prior attenuation cases was not limited to independent acts by a defendant; [3]-The outstanding arrest warrant was a critical intervening circumstance that was wholly independent of the illegal stop; [4]-It was especially significant that there was no evidence that the officer's illegal stop reflected flagrantly unlawful police misconduct.

Outcome

Judgment reversed. 5-3 decision; 2 dissents.

LexisNexis® Headnotes

 

 

Criminal Law & Procedure > Search & Seizure > Fruit of the Poisonous Tree > Attenuation

Constitutional Law > ... > Fundamental Rights > Search & Seizure > Exclusionary Rule

Criminal Law & Procedure > Search & Seizure > Exclusionary Rule > Rule Application & Interpretation

HN1  Attenuation

To enforce the Fourth Amendment’s prohibition against unreasonable searches and seizures, the United States Supreme Court has at times required courts to exclude evidence obtained by unconstitutional police conduct. But the Supreme 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.

 

Constitutional Law > ... > Fundamental Rights > Search & Seizure > Scope of Protection

HN2  Scope of Protection

The Fourth Amendment protects the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.

 

Constitutional Law > ... > Fundamental Rights > Search & Seizure > Exclusionary Rule

Criminal Law & Procedure > Search & Seizure > Exclusionary Rule > Rule Application & Interpretation

HN3  Exclusionary Rule

Under the United States Supreme Court’s precedents, the exclusionary rule encompasses both the primary evidence obtained as a direct result of an illegal search or seizure and evidence later discovered and found to be derivative of an illegality, the so-called fruit of the poisonous tree. But the significant costs of this rule have led the Supreme Court to deem it applicable only where its deterrence benefits outweigh its substantial social costs. Suppression of evidence has always been the Supreme Court's last resort, not its first impulse.

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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.