Utah v. Strieff Case Brief

Facts of the case

Utah Detective Douglas Fackrell received an anonymous tip about drug sales in a South Salt Lake residence, so he surveyed the area over a short period of time and speculated there was drug activity taking place. Fackrell saw Edward Joseph Strieff, Jr. leaving the residence and stopped him for questioning. During the stop, Fackrell discovered Strieff had an outstanding warrant and arrested him. During the lawful search after his arrest, Fackrell found methamphetamine and a drug pipe on Strieff’s person. The district court ruled that, although Fackrell did not have enough evidence to conduct an investigatory stop, the methamphetamine and drug paraphernalia obtained during the lawful search incident to arrest justified the admission of that evidence for trial. The Utah Court of Appeals affirmed the district court’s ruling, but the Utah Supreme Court reversed and held that the evidence should have been suppressed because the warrant that was the basis for the arrest was discovered during an unlawful investigatory stop.

CONCLUSION

The U.S. Supreme Court held that where an officer made an unconstitutional investigatory stop, learned during the stop that the suspect was subject to a valid arrest warrant, arrested the suspect, and seized incriminating evidence during a search incident to that arrest, the evidence the officer seized as part of the search incident to the arrest was admissible under the Fourth Amendment because the officer’s discovery of the arrest warrant attenuated the connection between the unlawful stop and the evidence seized incident to arrest.Thus, the Court further explained that the evidence Officer Fackrell seized incident to Strieff’s arrest is admissible based on an application of the attenuation factors from Brown v. Illinois , 422 U. S. 590, 95 S. Ct. 2254, 45 L. Ed. 2d 416 . In this case, there was no flagrant police misconduct therefore, Officer Fackrell’s discovery of a valid, pre-existing, and untainted arrest warrant attenuated the connection between the unconstitutional investigatory stop and the evidence seized incident to a lawful arrest.

  • Advocates: Tyler R. Green for the petitioner John F. Bash Assistant to the Solicitor General, for the United States as amicus curiae, for the petitioner Joan C. Watt for the respondent
  • Petitioner: Utah
  • Respondent: Edward Joseph Strieff
  • DECIDED BY:Roberts Court
  • Location: Salt Lake City District Court of Utah
Citation: 579 US _ (2016)
Granted: Oct 1, 2015
Argued: Feb 22, 2016
Decided: Jun 20, 2016
Utah v. Strieff Case Brief