Arizona v. Evans (1995)

Supreme Court of the United States

Arizona v. Evans, 514 U.S. 1 (1995)

 

CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.

This case presents the question whether evidence seized in violation of the Fourth Amendment by an officer who acted in reliance on a police record indicating the existence of an outstanding arrest warrant-a record that is later determined to be erroneous-must be suppressed by virtue of the exclusionary rule regardless of the source of the error. The Supreme Court of Arizona held that the exclusionary rule required suppression of evidence even if the erroneous information resulted from an error committed by an employee of the office of the Clerk of Court. We disagree.

In January 1991, Phoenix police officer Bryan Sargent observed respondent Isaac Evans driving the wrong way on a one-way street in front of the police station. The officer stopped respondent and asked to see his driver’s license. After respondent told him that his license had been suspended, the officer entered respondent’s name into a computer data terminal located in his patrol car. The computer inquiry confirmed that respondent’s license had been suspended and also indicated that there was an outstanding misdemeanor warrant for his arrest. Based upon the outstanding warrant, Officer Sargent placed respondent under arrest. While being handcuffed, respondent dropped a hand-rolled cigarette that the officers determined smelled of marijuana. Officers proceeded to search his car and discovered a bag of marijuana under the passenger’s seat.

The State charged respondent with possession of marijuana. When the police notified the Justice Court that they had arrested him, the Justice Court discovered that the arrest warrant previously had been quashed and so advised the police. Respondent argued that because his arrest was based on a warrant that had been quashed 17 days prior to his arrest, the marijuana seized incident to the arrest should be suppressed as the fruit of an unlawful arrest. Respondent also argued that “[t]he ‘good faith’ exception to the exclusionary rule [was] inapplicable … because it was police error, not judicial error, which caused the invalid arrest.” App. 5.

At the suppression hearing, the Chief Clerk of the Justice Court testified that a Justice of the Peace had issued the arrest warrant on December 13, 1990, because respondent had failed to appear to answer for several traffic violations. On December 19, 1990, respondent appeared before a pro tem Justice of the Peace who entered a notation in respondent’s file to “quash warrant.” Id., at 13.

The Chief Clerk also testified regarding the standard court procedure for quashing a warrant. Under that procedure a justice court clerk calls and informs the warrant section of the Sheriff’s Office when a warrant has been quashed. The Sheriff’s Office then removes the warrant from its computer records. After calling the Sheriff’s Office, the clerk makes a note in the individual’s file indicating the clerk who made the phone call and the person at the Sheriff’s Office to whom the clerk spoke. The Chief Clerk testified that there was no indication in respondent’s file that a clerk had called and notified the Sheriff’s Office that his arrest warrant had been quashed. A records clerk from the Sheriff’s Office also testified that the Sheriff’s Office had no record of a telephone call informing it that respondent’s arrest warrant had been quashed. Id., at 42-43.

At the close of testimony, respondent argued that the evidence obtained as a result of the arrest should be suppressed because “the purposes of the exclusionary rule would be served here by making the clerks for the court, or the clerk for the Sheriff’s office, whoever is responsible for this mistake, to be more careful about making sure that warrants are removed from the records.” Id., at 47. The trial court granted the motion to suppress because it concluded that the State had been at fault for failing to quash the warrant. Presumably because it could find no “distinction between State action, whether it happens to be the police department or not,” id., at 52, the trial court made no factual finding as to whether the Justice Court or Sheriff’s Office was responsible for the continued presence of the quashed warrant in the police records.***

Applying the reasoning of Leon to the facts of this case, we conclude that the decision of the Arizona Supreme Court must be reversed. The Arizona Supreme Court determined that it could not “support the distinction drawn … between clerical errors committed by law enforcement personnel and similar mistakes by court employees,” 177 Ariz., at 203, 866 P. 2d, at 871, and that “even assuming … that responsibility for the error rested with the justice court, it does not follow that the exclusionary rule should be inapplicable to these facts,” ibid.

This holding is contrary to the reasoning of Leon, supra; Massachusetts v. Sheppard, supra; and, Krull, supra. If court employees were responsible for the erroneous computer record, the exclusion of evidence at trial would not sufficiently deter future errors so as to warrant such a severe sanction. First, as we noted in Leon, the exclusionary rule was historically designed as a means of deterring police misconduct, not mistakes by court employees. See Leon, supra, at 916; see also Krull, supra, at 350. Second, respondent offers no evidence that court employees are inclined to ignore or subvert the Fourth Amendment or that lawlessness among these actors requires application of the extreme sanction of exclusion. See Leon, supra, at 916, and n. 14; see also Krull, supra, at 350-351. To the contrary, the Chief Clerk of the Justice Court testified at the suppression hearing that this type of error occurred once every three or four years. App. 37.

Finally, and most important, there is no basis for believing that application of the exclusionary rule in these circumstances will have a significant effect on court employees responsible for informing the police that a warrant has been quashed. Because court clerks are not adjuncts to the law enforcement team engaged in the often competitive enterprise of ferreting out crime, see Johnson v. United States, 333 U. S. 10, 14 (1948), they have no stake in the outcome of particular criminal prosecutions. Cf. Leon, supra, at 917; Krull, supra, at 352. The threat of exclusion of evidence could not be expected to deter such individuals from failing to inform police officials that a warrant had been quashed. Cf. Leon, supra, at 917; Krull, supra, at 352.

If it were indeed a court clerk who was responsible for the erroneous entry on the police computer, application of the exclusionary rule also could not be expected to alter the behavior of the arresting officer. ***

The judgment of the Supreme Court of Arizona is therefore reversed, and the case is remanded to that court for proceedings not inconsistent with this opinion.

It is so ordered.

JUSTICE O’CONNOR, with whom JUSTICE SOUTER and JUSTICE BREYER join, concurring.

The evidence in this case strongly suggests that it was a court employee’s departure from established recordkeeping procedures that caused the record of respondent’s arrest warrant to remain in the computer system after the warrant had been quashed. Prudently, then, the Court limits itself to the question whether a court employee’s departure from such established procedures is the kind of error to which the exclusionary rule should apply. The Court holds that it is not such an error, and I agree with that conclusion and join the Court’s opinion. The Court’s holding reaffirms that the exclusionary rule imposes significant costs on society’s law enforcement interests and thus should apply only where its deterrence purposes are “most efficaciously served,”***

JUSTICE STEVENS, dissenting.

***The Court seems to assume that the Fourth Amendment and particularly the exclusionary rule, which effectuates the Amendment’s commands-has the limited purpose of deterring police misconduct. Both the constitutional text and the history of its adoption and interpretation identify a more majestic conception. The Amendment protects the fundamental “right of the people to be secure in their persons, houses, papers, and effects,” against all official searches and seizures that are unreasonable. The Amendment is a constraint on the power of the sovereign, not merely on some of its agents. See Olmstead v. United States, 277 U. S. 438, 472-479 (1928) (Brandeis, J., dissenting). The remedy for its violation imposes costs on that sovereign, motivating it to train all of its personnel to avoid future violations. See Stewart, The Road to Mapp v. Ohio and Beyond: The Origins, Development and Future of the Exclusionary Rule in Search-and Seizure Cases, 83 Colum. L. Rev. 1365, 1400 (1983).

The exclusionary rule is not fairly characterized as an “extreme sanction,” ante, at 11 (internal quotation marks omitted). As Justice Stewart cogently explained, the implementation of this constitutionally mandated sanction merely places the government in the same position as if it had not conducted the illegal search and seizure in the first place. Given the undisputed fact in this case that the Constitution prohibited the warrantless arrest of respondent, there is nothing “extreme” about the Arizona Supreme Court’s conclusion that the State should not be permitted to profit from its negligent misconduct.

***

***[O]ne consequence of the Court’s holding seems immediately obvious. Its most serious impact will be on the otherwise innocent citizen who is stopped for a minor traffic infraction and is wrongfully arrested based on erroneous information in a computer data base. I assume the police officer who reasonably relies on the computer information would be immune from liability in a § 1983 action. Of course, the Court has held that respondeat superior is unavailable as a basis for imposing liability on his or her municipality. See Monell v. New York City Dept. of Social Servs., 436 U. S. 658, 663-664, n. 7 (1978). Thus, if courts are to on that same day that it happened. Fortunately, they weren’t all arrested.” App.37.

***The offense to the dignity of the citizen who is arrested, handcuffed, and searched on a public street simply because some bureaucrat has failed to maintain an accurate computer data base strikes me as equally outrageous. In this case, of course, such an error led to the fortuitous detection of respondent’s unlawful possession of marijuana, and the suppression of the fruit of the error would prevent the prosecution of his crime. That cost, however, must be weighed against the interest in protecting other, wholly innocent citizens from unwarranted indignity. In my judgment, the cost is amply offset by an appropriately “jealous regard for maintaining the integrity of individual rights.” Mapp v. Ohio, 367 U. S. 643, 647 (1961). For this reason, as well as those set forth by JUSTICE GINSBURG, I respectfully dissent.   

[Justice Ginsburg dissent omitted] 

License

Icon for the Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License

Criminal Procedure: Undergraduate Edition Copyright © 2022 by Christopher E. Smith is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License, except where otherwise noted.

Share This Book