Arizona v. Evans Case Brief

Facts of the Case

Isaac Evans 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. A subsequent search of his car revealed a bag of marijuana, and he was charged with possession. Evans moved to suppress the marijuana as the fruit of an unlawful arrest, since the misdemeanor warrant had been quashed before his arrest. The trial court granted the motion, but the Court of Appeals reversed on the ground that the exclusionary rule’s purpose would not be served by excluding evidence obtained because of an error by employees not directly associated with the arresting officers or their police department. In reversing, the Arizona Supreme Court rejected the distinction between clerical errors committed by law enforcement personnel and similar mistakes by court employees and predicted that the exclusionary rule’s application would serve to improve the efficiency of criminal justice system recordkeepers.


Did the First and Fourteenth Amendments require the North Carolina Department of Corrections to assist inmates in the preparation and filing of legal papers by providing adequate law libraries or adequate legal assistance?


“No. Chief Justice William H. Rehnquist delivered the opinion of the 7-2 majority. The Court held that the Supreme Court has jurisdiction to review cases from state courts that deal primarily with federal law. The Court also held that the Fourth Amendment was designed to protect against intrusions into a home or onto private property, or the conduct of police officers. The exclusionary rule therefore does not apply to the conduct of judicial officers.Justice Sandra Day O’Connor wrote a concurring opinion where she argued that the majority’s decision does not allow any evidence that is the result of a clerical error. Rather, the police must rely on accurate record-keeping systems in order to admit evidence found based on the information in those records. Justice David H. Souter and Stephen G. Breyer joined in the concurrence. In his concurrence, Justice Souter wrote that the majority’s opinion should be read as dealing solely with the issue of this type of clerical error, and not as dealing with the concept of how deterrence by exclusion extends to the government as a whole. Justice Breyer joined in the concurrence.Justice John Paul Stevens wrote a dissent and argued that the Fourth Amendment was meant as a constraint on governmental power as a whole, and not merely on its agents, namely the police. He also argued that the exclusionary rule does not place the government at a disadvantage in trial