Arizona v. Evans

514 U.S. 1 (1995).

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 court personnel.

Summary: Defendant was arrested during a routine traffic stop after the patrol car’s computer incorrectly indicated that there was an outstanding arrest warrant for the driver.  That mistaken information was caused by a court employee’s clerical error.

Following the arrest, the officer performed a search incident to the arrest and found marijuana.  Defendant moved to exclude any evidence of marijuana on the grounds that the arrest warrant was invalid and, therefore, the search was repugnant to the Fourth Amendment and triggered the exclusionary rule.

The Supreme Court disagreed with Defendant and held that the exclusionary rule did not apply to this case.

The Court reasoned that the narrow purpose of the exclusionary rule was to deter law enforcement personnel from engaging in conduct repugnant to the Fourth Amendment.  The exclusionary rule did not apply to mistakes by court employees.  The Court explained:

The exclusionary rule operates as a judicially created remedy designed to safeguard against future violations of Fourth Amendment rights through the rule’s general deterrent effect. [Citations.] As with any remedial device, the rule’s application has been restricted to those instances where its remedial objectives are thought most efficaciously served. [Citations.] Where ‘the exclusionary rule does not result in appreciable deterrence, then, clearly, its use.., is unwarranted.’ [Citation].

REFERENCE DESK

White v. State, 989 S.W.2d 108 (Tex. App. 1999):

In Arizona v. Evans, Evans was arrested during a routine traffic stop after a police computer showed an outstanding warrant for his arrest. During the ensuing search of Evans’ car, the police found marijuana, and Evans was charged with possession of an illegal substance. The police later discovered the warrant for Evans’ arrest had been quashed but a court clerk had failed to enter this information in the computer. Evans therefore argued the evidence of marijuana was obtained as a result of an illegal arrest and moved to suppress it. The Supreme Court held the “severe sanction” of exclusion was not warranted because the arresting officer acted in an objectively reasonable manner in relying upon the police computer record, and the erroneous record was the result of a clerical error by a court employee; therefore, exclusion would not appreciably deter similar errors in the future.

Whether an analysis similar to that employed in Evans applies to errors by law enforcement personnel is unsettled. The Evans Court expressly declined to address the issue because it was not adequately presented by the record. Arguably, this issue was presented in Mayorga because Haydee Mayorga was arrested as a result of erroneous information supplied by a police dispatcher. However, the applicability of the Evans exception issue was rendered immaterial by the Dallas Court of Appeals‘ holding that neither the federal nor the state exclusionary rule applied. See State v. Mayorga, 876 S.W.2d 176, 178 (Tex.App.—Dallas 1994). Because the exclusionary rule did not apply, the court was not required to determine the breadth of the Evans exception. Nonetheless, the Texas Court of Criminal Appeals remanded the case with instructions for the court of appeals to reconsider its decision in light of Evans. State v. Mayorga, 901 S.W.2d 943, 946 (Tex.Crim.App.1995). In compliance with the remand order, the Dallas Court of Appeals considered the Evans exception and concluded it did not apply to a mistake made by a police dispatcher, rather than a court employee. Mayorga, 938 S.W.2d at 83–84. However, as the court expressly recognized, its Evans analysis was immaterial in light of its holding that neither the federal nor the state exclusionary rule even applied to the evidence Mayorga sought to suppress. Id. at 84.