552 S.W.3d 832
Tenn.2018Background
- Officer Valentin arrested Angela Daniel for DUI, obtained a blood‑draw search warrant, transported her to a hospital, and blood was drawn.
- Officer Valentin did not leave a copy of the search warrant with Daniel; she testified it was likely an inadvertent oversight.
- Daniel moved to suppress the blood-test evidence under Tenn. R. Crim. P. 41(g)(6), which then mandated suppression when an executing officer did not leave a copy of the warrant.
- Trial court granted suppression; the Court of Criminal Appeals affirmed. The State appealed to the Tennessee Supreme Court.
- The State argued either Rule 41 required no suppression under these facts or that the Exclusionary Rule Reform Act (ERRA) excused the error as a clerical good‑faith mistake.
- The Tennessee Supreme Court held (1) ERRA was unavailable (per Lowe) and (2) adopted a narrow good‑faith exception to Rule 41 for inadvertent, nonprejudicial technical violations, reversing suppression on these facts.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Daniel) | Held |
|---|---|---|---|
| Whether failure to leave a copy of the warrant requires suppression under Rule 41 | Rule 41’s mandatory suppression should not apply where failure was inadvertent and caused no prejudice; courts should recognize a good‑faith exception | Rule 41(g)(6) mandates suppression when the executing officer did not leave a copy; suppression is required here | Court held Rule 41’s exclusion may yield to a narrow good‑faith exception when the noncompliance was inadvertent and nonprejudicial; suppression reversed |
| Whether ERRA saves the State by classifying the omission as a clerical good‑faith error | ERRA exempts evidence from suppression for good‑faith clerical errors, so evidence should be admissible | ERRA not invoked; Daniel argued suppression under Rule 41 | Court held ERRA unavailable (separation of powers concerns); State instead relied on common‑law good‑faith exception to Rule 41 |
Key Cases Cited
- State v. Reynolds, 504 S.W.3d 283 (Tenn. 2016) (discussing court’s authority to craft good‑faith exceptions to exclusionary rules)
- State v. Davidson, 509 S.W.3d 156 (Tenn. 2016) (applied good‑faith exception for a clerical affidavit error that did not prejudice defendant)
- State v. Davis, 185 S.W.3d 338 (Tenn. 2006) (explaining Rule 41 provides procedural protections beyond constitutional minima)
- Frisby v. United States, 79 F.3d 29 (6th Cir. 1996) (treating delivery of warrant as ministerial and not automatically voiding a search absent prejudice)
- United States v. Crumpton, 824 F.3d 593 (6th Cir. 2016) (refused suppression where defendant was shown a warrant at the scene and no prejudice resulted)