Bellamy v. Commonwealth, 724 S.E.2d 232

Officer Hall responded to a 911 domestic call at Bellamy's residence and spoke with Bellamy's adult stepson; after separating them, Hall obtained their full identifiers and relayed them to a dispatcher.
Dispatcher informed Hall there was an outstanding arrest warrant for Bellamy but provided no further details.
Relying on the dispatch information, Hall arrested Bellamy and conducted a search incident to arrest, recovering marijuana and an unused .22 bullet.
Hall then called the warrant office to verify the warrant and learned it had been previously served and was no longer outstanding.
Bellamy was charged with possession of ammunition by a felon; after suppression motion denial, he was convicted; on appeal, he contends suppression was required for the bullet evidence, based on erroneous dispatcher information.
The appellate court affirmed, holding that Hall reasonably relied on the dispatch information and the exclusionary rule did not require suppression under the circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether arrest and search based on dispatcher’s erroneous warrant info violated the Fourth Amendment	Bellamy argues the arrest/search violated Fourth Amendment	Commonwealth argues good-faith reliance on dispatcher info was reasonable	No error; evidence not suppressed due to good-faith reliance

Mapp v. Ohio, 367 U.S. 643 (1961) (incorporation of the exclusionary rule to the states)
Weeks v. United States, 232 U.S. 383 (1914) (origin of the exclusionary rule)
United States v. Leon, 468 U.S. 897 (1984) (deterrence and good-faith exception; objective reasonableness; marginal deterrence)
Arizona v. Evans, 514 U.S. 1 (1995) (miscommunication post-arrest and suppression not required)
Herring v. United States, 555 U.S. 135 (2009) (good-faith reliance; deterrence not served by exclusion in this fact pattern)