Utah v. Strieff
579 U.S. ___ (2016) (2016)
Rule of Law:
Evidence seized during a search incident to a lawful arrest is admissible under the attenuation doctrine, even if the arrest warrant was discovered during an unconstitutional investigatory stop, so long as the stop was not purposeful or flagrant misconduct.
Facts:
- After receiving an anonymous tip about narcotics activity, Detective Douglas Fackrell conducted intermittent surveillance on a South Salt Lake City residence for about a week.
- Fackrell observed visitors making short stays, which raised his suspicion of drug dealing.
- He saw Edward Strieff exit the house and walk towards a convenience store.
- In the store's parking lot, Fackrell detained Strieff without reasonable suspicion, identified himself, and demanded Strieff's identification.
- Fackrell relayed Strieff's information to a police dispatcher, who reported that Strieff had an outstanding arrest warrant for a traffic violation.
- Fackrell then arrested Strieff pursuant to that warrant.
- During a search incident to the arrest, Fackrell discovered a baggie of methamphetamine and drug paraphernalia on Strieff's person.
Procedural Posture:
- The State of Utah charged Strieff with unlawful possession of methamphetamine and drug paraphernalia in a state trial court.
- Strieff filed a motion to suppress the evidence, arguing it was derived from an unlawful stop.
- The trial court denied the motion, and Strieff entered a conditional guilty plea, reserving his right to appeal.
- The Utah Court of Appeals, an intermediate appellate court, affirmed the trial court's decision.
- On appeal, the Utah Supreme Court, the state's highest court, reversed the lower court, holding that the evidence was inadmissible.
- The U.S. Supreme Court granted certiorari to review the decision of the Utah Supreme Court.
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Issue:
Does the attenuation doctrine permit the admission of evidence seized during a search incident to an arrest on a valid, pre-existing warrant that was discovered during an unconstitutional investigatory stop?
Opinions:
Majority - Justice Thomas
Yes. The evidence 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 stop and the evidence. The court applied the three-factor test from Brown v. Illinois. First, the temporal proximity was short, which favors suppression. However, the second factor, the presence of intervening circumstances, strongly favors the state; the discovery of a valid, pre-existing, and untainted arrest warrant was a critical intervening circumstance that compelled the officer to arrest Strieff. Third, and most significantly, the purpose and flagrancy of the misconduct also favors the state, as the officer's stop was at most negligent—a good-faith error in judgment connected to a bona fide investigation—not a purposeful or flagrant violation of the Fourth Amendment. The second and third factors outweigh the first, breaking the causal chain between the illegal stop and the discovery of the contraband.
Dissenting - Justice Sotomayor
No. The evidence should be suppressed because it was discovered by exploiting an illegal stop. The Court's holding validates suspicionless stops and allows police to unlawfully detain individuals on a whim to fish for one of the millions of outstanding warrants for minor offenses. The warrant check was not an intervening circumstance but was part and parcel of the officer's illegal 'expedition for evidence.' This decision encourages police misconduct, which disproportionately affects minority communities, and treats citizens as 'the subject of a carceral state, just waiting to be cataloged.' The officer's stop was not an isolated act of negligence but is indicative of systemic practices where police use warrant checks to get around Fourth Amendment protections.
Dissenting - Justice Kagan
No. Admitting the evidence fails the cost-benefit analysis of the exclusionary rule because it does not deter unconstitutional police conduct. Applying the Brown factors, all three point toward suppression. First, the temporal proximity was immediate. Second, the stop was purposeful and calculated for investigatory reasons, not an innocent mistake. Third, the discovery of a warrant is not an unforeseeable 'intervening circumstance' that breaks the causal chain; rather, it is an 'eminently foreseeable consequence' of a stop, given the staggering number of outstanding warrants. This ruling creates a perverse incentive for officers to conduct unconstitutional stops, knowing that the routine discovery of a warrant will cleanse the illegality and make any evidence admissible.
Analysis:
This decision significantly narrows the scope of the exclusionary rule by expanding the attenuation doctrine. It establishes that a valid, pre-existing arrest warrant acts as a powerful intervening event that can purge the taint of an initial unconstitutional stop. The ruling creates a crucial distinction between negligent police errors and purposeful, flagrant misconduct, making the officer's subjective intent more central to suppression hearings. This may incentivize police to conduct stops on less than reasonable suspicion, hoping that a routine warrant check—on one of the millions of Americans with an outstanding warrant—will retroactively justify a search for evidence.
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