Utah v. Strieff

PETITIONER: Utah
RESPONDENT: Edward Joseph Strieff
LOCATION: Salt Lake City District Court of Utah

DOCKET NO.: 14-1373
DECIDED BY: Roberts Court (2016- )
LOWER COURT: Utah Supreme Court

CITATION: 579 US (2016)
GRANTED: Oct 01, 2015
ARGUED: Feb 22, 2016
DECIDED: Jun 20, 2016

ADVOCATES:
John F. Bash - Assistant to the Solicitor General, for the United States as amicus curiae, for the petitioner
Tyler R. Green - for the petitioner
Joan C. Watt - for the respondent

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.

Question

Should evidence seized incident to a lawful arrest on an outstanding warrant be suppressed because the warrant was discovered during an investigatory stop later found to be unlawful?

Media for Utah v. Strieff

Audio Transcription for Oral Argument - February 22, 2016 in Utah v. Strieff

Audio Transcription for Opinion Announcement - June 20, 2016 in Utah v. Strieff

John G. Roberts, Jr.:

And Justice Thomas has our opinion this morning in case 14-1373 Utah versus Strieff.

Clarence Thomas:

This case comes to us on a Writ of Certiorari to the Supreme Court of Utah.

Narcotics detective, David Fackrell, conducted surveillance on a South Salt Lake City residence, because police received an anonymous tip about drug activity at a house or at the house he was observing.

Officer Fackrell observed a number of people making brief visits to the house over a course of a week.

This made him suspicions that the occupants were in fact dealing drugs.

After observing, respondent Edward Strieff leave the residence, Officer Fackrell detained Strieff to ask what he was doing at the house.

Officer Fackrell requested Strieff's identification and relayed the information to a police dispatcher.

The dispatcher informed Officer Fackrell that Strieff had an outstanding arrest warrant for a traffic violation.

Officer Fackrell arrested Strieff, searched him and found drugs and drug related items on this person.

Strieff moved to suppress the evidence arguing that it was derived from an unlawful investigatory stop.

The State argued, however, that the discovery of the evidence was attenuated from the officer's unlawful conduct.

The attenuation doctrine allows evidence to be admitted when the connection between unconstitutional police conduct and the evidence is sufficiently remote or has been interrupted by some intervening circumstance.

The trial court denied the suppression motion and the Utah's Court of Appeals affirmed.

The Supreme Court of Utah in turn reversed, however, and held that the attenuation exception did not apply.

In its view only a, “voluntary act of the defendant’s freewill as in a confession or consent to search”, sufficiently breaks the connection between an illegal search and the discovery of evidence.

We granted certiorari to resolve disagreement about how the attenuation doctrine applies where an unconstitutional detention leads to the discovery of a pre-existing valid arrest warrant.

In an opinion filed with the clerk today, we reverse the Supreme Court of Utah.

We hold that the drug evidence discovered incident to Strieff's arrests is admissible based on an application of the attenuation standard announced in Brown v. Illinois.

The standard announced in Brown requires us to consider three factors.

The first, “temporal proximity” between the initially unlawful stop and the search, favors suppressing the evidence.

Officer Fackrell discovered drug contraband on Strieff only minutes after the illegal stop.

The second factor, the presence of intervening circumstances, strongly favors the State.

Officer Fackrell's decision to search Streiff resulted from his discovery of a valid arrest warrant predating the investigation and entirely apart from the initially unconstitutional stop.

The third factor, the purpose and flagrancy of the official misconduct also strongly favors the state.

Officer Fackrell was at most negligent, but his errors in judgment hardly amounted to a purposeful or flagrant violation of Strieff's Fourth Amendment rights.

We emphasize that there is no indication that the stop was part of a systematic or systemic or recurrent police misconduct by the South Salt Lake City Police Department.

Thus, because there was no flagrant police misconduct, Officer Fackrell's discovery of a valid preexisting and untainted arrest warrant attenuated the connection between the unconstitutional investigatory stop and the evidence seized incident to a lawful arrest.

We do not hold that Officer Fackrell's initial stop of Streiff was constitutional nor do we preclude Streiff from seeking a different kind of legal remedy for the violation of his Fourth Amendment rights.

We hold only that one particular remedy excluding evidence from his criminal trial does not apply in these circumstances.

For these reasons and for the others set forth in our opinion we reverse the judgment of the Supreme Court of Utah.

Sarah from Law Aspect

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