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].

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