Utah v. Strieff
Following is the case brief for Utah v. Strieff, 136 S. Ct. 2056 (2016)
Case Summary of Utah v. Strieff:
- A police officer, suspecting that a house was being used for drug transactions, stopped Strieff when he walked out of the house.
- The officer asked for identification. When Strieff provided it, the officer ran a check on his name, discovering that there was a warrant for his arrest for unpaid parking tickets.
- The officer then arrested Strieff. Incident to the arrest, the officer found drugs on Strieff.
- Strieff moved to suppress the evidence found during the search as a violation of the Fourth Amendment. The Utah Supreme Court suppressed the evidence.
- The U.S. Supreme Court, however, allowed the evidence under the “attenuation exception” to the Fourth Amendment’s exclusionary rule.
Utah v. Strieff Case Brief
Statement of the Facts:
- Initial Stop and Search
A police officer, conducting surveillance of a residence, suspected that drug transactions were occurring in the residence. When Strieff walked out of the residence, the officer stopped him and asked for identification. Upon learning Strieff’s name, the officer ran a check to learn that Strieff had an outstanding arrest warrant for unpaid parking tickets. The officer then arrested Strieff and seized drugs from Strieff’s person.
- Motion to Supress
Strieff moved to suppress the evidence discovered on his person. He argued that the investigatory stop was unlawful. Therefore, any evidence obtained as a result of the stop must be excluded from trial under the Fourth Amendment, as an unlawful search and seizure.
- The lower Utah courts refused to exclude the evidence.
- On appeal to the Utah Supreme Court, the court suppressed the evidence obtained from the search.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Does a search of a database to learn that a person has an arrest warrant create the attenuation sufficient to allow evidence of a search at trial, even though the initial investigatory stop was unlawful? Yes.
The decision of the Utah Supreme Court is reversed.
Rule of Law or Legal Principle Applied:
If, after an unlawful investigatory stop, police discover that a person has an arrest warrant, then any evidence discovered after that person’s arrest is allowable in court, and there is no Fourth Amendment violation absent flagrant police misconduct.
The Court reasoned that the exclusionary rule – which excludes evidence from trial that was obtained in violation of the Fourth Amendment – can deter unlawful police conduct. Yet, if the benefits of the deterrence are outweighed by the social cost to letting a criminal go free then the exclusionary rule may not always be employed.
- Exceptions to the Exclusionary Rule
The Court noted three exceptions to the exclusionary rule: the independent source doctrine, the inevitable discovery doctrine, and the attenuation doctrine. This case implicates the attenuation rule. There are three tests for attenuation are whether:
- The illegal police conduct and the discovery of evidence were close in time?
- There was some intervening factors between the misconduct and the discovery of evidence?
- The police misconduct was flagrant?
- Applying the Attenuation Doctrine
As a threshold matter, the Court conceded that the officer’s initial stop of Strieff was unlawful. With regard to the three tests, the Court also conceded that the misconduct and the discovery of evidence were close in time. However, the Court found that the existence of the arrest warrant was an intervening factor making the distance between the illegality and the seizure of evidence attenuated. The Court added that the police misconduct was mere negligence and was not flagrant.
Concurring and Dissenting Opinions:
Dissenting Opinion (Kagan):
The existence of the arrest warrant does not provide the “attenuation” the Court believes exists. Indeed, all three tests demonstrate there was not sufficient attenuation. The seizure of evidence happened moments after the initial stop, the arrest warrant was not the type of intervening factor that changes the Fourth Amendment analysis, and the officer’s misconduct was indeed flagrant.
Dissenting Opinion (Sotomayor):
The Court’s decision means that police are now able to conduct arbitrary stops of anyone, demand their identification, and run a check for traffic warrants – even though you have done nothing wrong. The Fourth Amendment was meant to prohibit that kind of police abuse of authority. The Court’s opinion shamefully downplays the seriousness of what it now allows police to do, and the police already abuse their power of “investigatory stops” frequently. That is not justice.
Utah v. Strieff is important for two reasons. First, it stretches the “attenuation doctrine” to new place that some scholars may argue goes past the point for rationality, and thus limits the exclusionary rule for Fourth Amendment violations. Second, as Justice Sotomayor’s dissent suggests, it appears to allow the kind of “investigatory stops” that have plagued inner cities for the last decade, in which minorities have been stopped in numbers far higher than those of whites.