Brierley v. Layton City, 2016 UT 46

Layton police responded to a reported hit-and-run; dispatch gave the SUV plate and the registered owner’s home address.
Officers arrived, saw the SUV in the garage and a housekeeper who said Brierley (the homeowner’s daughter) had come inside appearing intoxicated.
The housekeeper invited officers in; they initially declined, consulted a city attorney, and one officer retrieved his tablet to begin drafting a warrant application.
While the front door was open and the housekeeper went downstairs, one officer stepped inside and later the second officer joined; inside they proceeded to prepare a warrant and then obtained statements, a breath test, and identification info from Brierley in the garage.
Brierley was charged with DUI and related offenses and moved to suppress evidence obtained after the warrantless entry; the district court granted suppression.
The Utah Court of Appeals reversed, applying Souza’s four-factor approach to inevitable discovery; the Utah Supreme Court granted certiorari and reinstated the suppression order, holding the City failed to prove inevitable discovery under Nix.

Issue	Brierley (Plaintiff) Argument	Layton City (Defendant) Argument	Held
Whether evidence obtained after warrantless entry is admissible under the inevitable-discovery exception	Entry violated Fourth Amendment and evidence must be suppressed; police would not inevitably have discovered evidence lawfully	Officers were in the process of obtaining a warrant and would have inevitably obtained the same evidence through a lawful warrant	Held for Brierley: City failed to prove by preponderance that a warrant would have been sought and obtained and that the same evidence would have been discovered lawfully; suppression affirmed

Nix v. Williams, 467 U.S. 431 (establishes the inevitable-discovery exception to the exclusionary rule)
Mapp v. Ohio, 367 U.S. 643 (adoption of exclusionary rule for Fourth Amendment violations)
Payton v. New York, 445 U.S. 573 (warrantless entry into a home presumptively unreasonable)
State v. Topanotes, 76 P.3d 1159 (Utah 2003) (inevitable-discovery requires independence from the illegality and is rarely met when individual behavior is pivotal)
State v. Tripp, 227 P.3d 1251 (Utah 2010) (rejecting inevitability where officers threatened to seek a warrant but took no steps)
United States v. Souza, 223 F.3d 1197 (10th Cir. 2000) (articulated four-factor approach used by court of appeals)
United States v. Christy, 739 F.3d 534 (10th Cir. 2014) (example where another officer would have independently obtained a warrant)
United States v. Vasquez De Reyes, 149 F.3d 192 (3d Cir. 1998) (observing the doctrinal fit is stronger for tangible evidence than ephemeral statements)