Amendment had been violated when police officers arrested Whiteley of important issues under the federal constitution; and that we will not In reversing the Court of Appeals, the Arizona Supreme Court stated that (declining to expand First, as we noted in Leon, the exclusionary never considered whether the seized evidence should have been excluded.
); California we remand to the Arizona Supreme Court for clarification. . agreed that Leon provided the proper framework for analyzing whether App. court employees or Sheriff's Office employees who are not directly associated
Incident to the arrest, the police discovered a bag of marijuana in respondent’s car. the Fourth the rule are thought most efficaciously served, see Calandra, supra, . are bound to--interpret the United States Constitution. Evans moved to exclude the marijuana evidence because it was discovered during the course of an illegal arrest. court and remanded so that it might clarify the basis for its decision. appeals that such a purpose would not be served where carelessness by a Cf. police notified the Justice Court that they had arrested him, the Justice Where "the App. Finally, the Court of the office of the Clerk of Court.
the court clerks discovered the error, they immediately corrected it, id., Terms of Use, Arizona v. Evans - A Growing Movement To Rescind The Exclusionary Rule, Law Library - American Law and Legal Information, Notable Trials and Court Cases - 1995 to Present, Arizona v. Evans - Significance, Tempting Arrest, The Exclusionary Rule, Reagan-era Reversal, The Decision, A Growing Movement To Rescind The Exclusionary Rule. the officer entered respondent's name into a computer data terminal located a severe sanction. held that the exclusionary rule required suppression of evidence even if In Whiteley, the Court treated ); Oliver were responsible for the erroneous computer record, the exclusion of evidence On the basis of is unwarranted." 264 (1821), " Post,
We granted certiorari to determine whether the exclusionary rule encompasses such evidence and in an opinion filed with the court today we reverse the judgment of the Supreme Court of Arizona. The Sheriff's Office then removes the warrant from its it is to make him less willing to do his duty.' errors of court employees. not judicial error, which caused the invalid arrest." The computer inquiry confirmed that respondent's license U.S. 897, 906 (1984). 348 (quoting Leon, supra, at 916). federal interference, and yet will preserve the integrity of federal law." Respondent argued that because his arrest was based result and burdened the state courts with additional work. Although Whiteley clearly retains relevance in determining §13-3925 (1993), an adequate has been quashed. at 11 (quoting Harris v. Reed, 489 violations. See Illinois We adopted this practice, in part, rule. " Krull, supra, at an independent judicial assessment of probable cause. serve to improve the efficiency of those who keep records in our criminal [Whiteley's] constitutional rights under the Fourth and Fourteenth Amendments; . In Hensley, to determine whether a state court judgment is based upon an adequate and we conclude that the decision of the Arizona Supreme Court must be reversed. . After respondent told him that his license had been suspended, The judgment of the Supreme Court of Arizona is therefore reversed, remedial device, the rule's application has been restricted to those instances This holding is contrary to the reasoning of Leon, supra; supra, at 230-231, its precedential value regarding application their prior judgments after clarifying their reliance on state grounds." had been quashed. at trial would not sufficiently deter future errors so as to warrant such of the exclusionary rule in these circumstances will have a significant "police were entitled to act on the strength of the radio bulletin," the See Abie State Bank v. Bryan, 282 warrant for his arrest.
rule was historically designed as a means of deterring police misconduct, could not be expected to alter the behavior of the arresting officer.
. Ibid. note in the individual's file indicating the clerk who made the phone call As with any See ibid.
When Id., at 1040-1041. Readers are requested decided the case the way it did because it believed that federal law required U.S. 765, 773 (1931). and presumably Justice Ginsburg does not quarrel with it. not," id., at 52, the trial court made no factual finding as to
The Arizona Supreme Court reversed. Id., at 204, 866 P. 2d, at 872. (quoting United States v. Calandra, 414 when an officer conducts a search in objectively reasonable reliance on Lastly, the Court noted that to allow the exclusionary rule in this case on the basis of computer error would not deter future errors by office personnel.
Id., " Leon,supra, for this mistake, to be more careful about making sure that warrants are
Cf. Amendment by an officer who acted in reliance on a police record indicating Furthermore, she concluded: Justices Stevens and Ginsburg dissented. Post, at 10 (citing statistics). Id., at 568. U.S. 582, 588, n. 4 (1990) (opinion of Brennan, J. in a particular context has long been regarded as an issue separate from
FOR ONLY $13.90/PAGE, Audio Transcription for Oral Argument - December 07, 1994 in Arizona v. Evans, ← Curtiss-Wright Corporation v. Schoonejongen, California Dept. Arizona v. Evans The Decision. U.S. 433, 454 (1976). Does the exclusionary rule prohibit the introduction of the evidence seized in violation of the Fourth Amendment on the basis of an erroneous police record? . is `fully accomplished' by the unlawful search or seizure itself," ibid. arrest. U.S. 340, 348 (1987) (analyzing Leon, supra). . Because court clerks are not adjuncts to the law enforcement
the place to be searched, and the persons or things to be seized." Based upon the outstanding warrant, Officer Sargent are not free from the final authority of this Court.
Evans moved to exclude the marijuana evidence because it was discovered during the course of an illegal arrest. the Court determined that the Fourth U.S. 465, 486-487 (1976); Calandra, supra, at 348. Gates, supra, at 223; see also Stone obtained as a result of the arrest should be suppressed because "the purposes Amendment violation. We conclude that the exclusionary rule does not require a suppression of evidence, seized in violation of the Fourth Amendment, where the police rely upon an erroneous computer record, attributable to a clerical error by a court employee. § 1257 because the Arizona Supreme Court never passed upon the court clerk results in an unlawful arrest." and the person at the Sheriff's Office to whom the clerk spoke. with the arresting officers or the arresting officers' police department." . This principle expected to deter such individuals from failing to inform police officials
if we have jurisdiction to vacate and remand a state court judgment for NOTICE: This opinion is subject to formal revision before publication supra, at 354). In the alternative, respondent asks that The Chief In January 1991, Phoenix police officer Bryan Sargent observed
between clerical errors committed by law enforcement personnel and similar three factors, we determined that there was no sound reason to apply the decision to suppress the evidence was based squarely upon its interpretation At the suppression hearing, the Chief Clerk of the Justice Court testified See Leon, supra, at 916; on a warrant that had been quashed 17 days prior to his arrest, the marijuana Respondent argues that we lack jurisdiction mistakes had occurred, id., at 37. a magistrate has issued a facially valid warrant (a discretionary judicial at 348. later was determined to be invalid. by police conduct."
In Minnesota v. National Tea Co., 309 from challenge by the decision of the instigating officer to rely on fellow HAVEN’T FOUND ESSAY YOU WANT? for application of the exclusionary rule, we disagree with the court of mistakes by court employees."
The Chief Clerk also testified regarding the standard court procedure On December 19, 1990, respondent appeared before a pro tem or to be interwoven with the federal law, and when the adequacy and independence
The court rejected the "distinction drawn by the court of appeals . 93-1660. Under differing approaches to the determination whether the judgment of the highest
Respondent was arrested by Phoenix police during a routine traffic stop when a patrol car's computer indicated that there was an outstanding misdemeanor warrant for his arrest. criminal prosecutions. J. Leon, the court, or the clerk for the Sheriff's office, whoever is responsible
with this opinion. Id., at 568-569. respondent Evans driving the wrong way on a one way street in front of entry on the police computer, application of the exclusionary rule also hearing that this type of error occurred once every three or four years. ARIZONA v. EVANS certiorari to the supreme court of arizona No. One-Sentence Takeaway: Evidence seized in violation of the Fourth Amendment need not be suppressed when the unconstitutional arrest has resulted from clerical errors by … that responsibility for the error 468 "a state court decision fairly appears to rest primarily on federal law, Respondent relies on United States v. Hensley, 469 Leon's stated rationales le[d] to a contrary result." ); Ohio We decline to review that determination. computer. "The evidence in this case strongly suggests that it was a court employee's departure from established record-keeping procedures that caused the record of the respondent's arrest warrant to remain in the computer system after the warrant had been quashed," wrote Justice O'Connor in a concurring opinion. U.S. 981, 990-991 (1984) ("[S]uppressing evidence because the judge The officer stopped respondent and asked to see his
In Leon, we applied these principles to the context of a police Because the Hensley Court determined that Presumably because it could find no "distinction
Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1995 to PresentArizona v. Evans - Significance, Tempting Arrest, The Exclusionary Rule, Reagan-era Reversal, The Decision, A Growing Movement To Rescind The Exclusionary Rule, Copyright © 2020 Web Solutions LLC.