Law School Case Brief
United States v. Santa - 180 F.3d 20 (2d Cir. 1999)
The good faith exception to the exclusionary rule applies to evidence seized in violation of U.S Const. amend. IV by an officer acting in objectively reasonable reliance on an erroneous police record indicating the existence of an outstanding arrest warrant, so long as court employees were responsible for the error.
Police arrested defendant and seized from his possession plastic bags containing crack cocaine. The officers made the arrest based on a police computer record which indicated that defendant was wanted on an outstanding warrant. Unbeknownst to the arresting officers, the warrant had been vacated 17 months earlier, but remained in the statewide police computer network because court employees had failed to notify the proper law enforcement agency to remove it. Prior to trial, defendant filed a motion to suppress the drug evidence, arguing that it was the product of an unlawful arrest on an invalid warrant. The district court denied defendant's motion. Following a bench trial, defendant was convicted of violating 21 U.S.C.S. §§ 812, 841(a)(1) and 841(b)(1)(C) by possessing crack cocaine with intent to distribute. Defendant appealed.
Did the officer's conduct fall within the good faith exception?
The Court affirmed defendant's drug convictions, finding that his motion to suppress evidence was properly denied by the trial court under a good faith exception to the exclusionary rule applying to arrests based on erroneous police records. The Court held that the officers' conduct fell within a recently established good faith exception to the exclusionary rule governing situations where law enforcement officers rely on police records that contain erroneous information resulting from clerical errors of court employees.
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