State v. Rodriguez
1606007067
| Del. Super. Ct. | Dec 21, 2016Background
- On June 9, 2016, Dover police arrested Johan Rodriguez after an officer acted on an informant’s tip that Rodriguez was hiding from Probation & Parole and in possession of controlled substances.
- The informant (allegedly previously reliable) described Rodriguez’s clothing, location, and asserted drug possession; officers said they verified an outstanding warrant before arresting him.
- Rodriguez was found wearing similar clothing; police allege he possessed crack and heroin and made incriminating statements post-arrest.
- Rodriguez moved to suppress evidence, arguing the only warrant had been cleared on May 23, 2016, so no valid warrant existed at the time of arrest.
- Trial court considered whether the arresting officer had probable cause based on (a) an invalid warrant and (b) the informant’s tip, and whether evidence from the arrest must be suppressed under the Delaware Constitution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of warrant-based probable cause | Officer reasonably relied on a warrant verified before arrest | No valid arrest warrant existed (it had been cleared May 23) | Warrant was invalid; reliance on it did not supply probable cause |
| Sufficiency of informant tip to establish probable cause | Informant was known/reliable and tip was corroborated by police (location, apparel) | Tip lacked detail (only location/appearance) and insufficiently corroborated to establish probable cause | Tip insufficient under totality-of-circumstances to supply probable cause |
| Remedy for unlawful arrest under Delaware law | N/A (State advanced evidence) | Suppress all evidence obtained as fruit of illegal arrest | Evidence obtained as result of illegal arrest suppressed under Delaware Constitution |
| Applicability of federal cases on invalid warrants | Whiteley and related authority permit arresting officers to rely on other officers' representations | Defendant distinguishes Whiteley because facts differ | Court applied Whiteley: an erroneously issued warrant cannot provide probable cause |
Key Cases Cited
- Whiteley v. Warden, Wyo. State Penitentiary, 401 U.S. 560 (U.S. 1971) (an erroneously issued warrant cannot provide probable cause for an arrest)
- Henry v. State, 588 A.2d 1142 (Del. 1991) (known informant’s detailed, corroborated tip of future conduct can supply probable cause)
- Stafford v. State, 59 A.3d 1223 (Del. 2012) (defines probable cause standard)
- LeGrande v. State, 947 A.2d 1103 (Del. 2008) (factors for evaluating informant tip reliability and corroboration)
- Berg v. County of Allegheny, 219 F.3d 261 (3d Cir. 2000) (follows Whiteley: invalid warrant cannot confer probable cause)