THIS CASEBOOK contains a selection of 52 U. S. Supreme Court Decisions issued in the Court's term that ended June 27, 2016.
In Utah v. Strieff, (2016), the Supreme Court granted certiorari to resolve disagreement about how the attenuation doctrine applies where an unconstitutional detention leads to the discovery of a valid arrest warrant.
The Court holds, in Strieff, that the subsequent "discovery of a warrant for an unpaid parking ticket will forgive a police officer's violation of your Fourth Amendment rights." Utah v. Strieff, ibid., Sotomayor, J., dissenting.
Under the Court's precedents, the exclusionary rule encompasses both the "primary evidence obtained as a direct result of an illegal search or seizure" and, as relevant in Strieff, "evidence later discovered and found to be derivative of an illegality," the so-called "'fruit of the poisonous tree.'" Segura v. United States, 468 U. S. 796, 804 (1984). The significant costs of this rule have led the Court to deem it "applicable only . . . where its deterrence benefits outweigh its substantial social costs." Hudson v. Michigan, 547 U. S. 586, 591 (2006) (internal quotation marks omitted). "Suppression of evidence . . . has always been our last resort, not our first impulse." Ibid. Utah v. Strieff, ibid.
There are several exceptions to the general rule. Three of these exceptions involve the causal relationship between the unconstitutional act and the discovery of evidence. First, the independent source doctrine allows trial courts to admit evidence obtained in an unlawful search if officers independently acquired it from a separate, independent source. See Murray v. United States, 487 U. S. 533, 537 (1988). Second, the inevitable discovery doctrine allows for the admission of evidence that would have been discovered even without the unconstitutional source. See Nix v. Williams, 467 U. S. 431, 443-444 (1984). Third, and at issue in Strieff, is the attenuation doctrine: Evidence is admissible when the connection between unconstitutional police conduct and the evidence is remote or has been interrupted by some intervening circumstance, so that "the interest protected by the constitutional guarantee that has been violated would not be served by suppression of the evidence obtained." Hudson, supra, at 593. Utah v. Strieff, ibid.
In Utah v. Strieff, (2016), the Supreme Court granted certiorari to resolve disagreement about how the attenuation doctrine applies where an unconstitutional detention leads to the discovery of a valid arrest warrant.
The Court holds, in Strieff, that the subsequent "discovery of a warrant for an unpaid parking ticket will forgive a police officer's violation of your Fourth Amendment rights." Utah v. Strieff, ibid., Sotomayor, J., dissenting.
Under the Court's precedents, the exclusionary rule encompasses both the "primary evidence obtained as a direct result of an illegal search or seizure" and, as relevant in Strieff, "evidence later discovered and found to be derivative of an illegality," the so-called "'fruit of the poisonous tree.'" Segura v. United States, 468 U. S. 796, 804 (1984). The significant costs of this rule have led the Court to deem it "applicable only . . . where its deterrence benefits outweigh its substantial social costs." Hudson v. Michigan, 547 U. S. 586, 591 (2006) (internal quotation marks omitted). "Suppression of evidence . . . has always been our last resort, not our first impulse." Ibid. Utah v. Strieff, ibid.
There are several exceptions to the general rule. Three of these exceptions involve the causal relationship between the unconstitutional act and the discovery of evidence. First, the independent source doctrine allows trial courts to admit evidence obtained in an unlawful search if officers independently acquired it from a separate, independent source. See Murray v. United States, 487 U. S. 533, 537 (1988). Second, the inevitable discovery doctrine allows for the admission of evidence that would have been discovered even without the unconstitutional source. See Nix v. Williams, 467 U. S. 431, 443-444 (1984). Third, and at issue in Strieff, is the attenuation doctrine: Evidence is admissible when the connection between unconstitutional police conduct and the evidence is remote or has been interrupted by some intervening circumstance, so that "the interest protected by the constitutional guarantee that has been violated would not be served by suppression of the evidence obtained." Hudson, supra, at 593. Utah v. Strieff, ibid.
