United States v. Jose Clariot
2011 U.S. App. LEXIS 17719
| 6th Cir. | 2011Background
- Three men landed a private plane at an unstaffed Jackson, Tennessee airport at about 9:00 p.m. and were approached by five officers who requested IDs.
- A warrant check on the men yielded no incriminating results; identifications were returned and officers engaged in a casual conversation with the pilots.
- After about 10–15 minutes, officers sought consent to search the plane; the pilots refused and then departed for Nashville the same night.
- Subsequently, 70 kilograms of cocaine were discovered in Nashville during a separate investigation of the aircraft.
- Defendants moved to suppress Lieutenant Carneal’s observations of the Jackson airport encounter, which the district court suppressed.
- The district court held the suppression appropriate and the government appealed under 18 U.S.C. § 3731.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether suppression of Carneal’s observations was proper | Guzman/Toledo argued the encounter tainted later discovery | Government argued attenuated link; no sufficient taint | Yes, suppressions reversed; observations not tainted evidence |
| Did an illegal seizure occur at the Jackson airport | Defendants contended seizure violated Fourth Amendment | Government argued no remediable taint in later evidence | Court assumed possible initial illegality for argument, but held not causally connected to later discovery |
| Should the later cocaine be suppressed as fruit of illegal conduct | Suppression warranted to deter Fourth Amendment violations | Deterrence not proportional; attenuated and independent evidence | No suppression; evidence not product of illegal seizure and deterrence insufficient |
Key Cases Cited
- Weeks v. United States, 232 U.S. 383 (U.S. 1914) (establishes exclusionary rule for federal seizures)
- Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusionary rule applied to states via Fourteenth Amendment)
- Elkins v. United States, 364 U.S. 206 (U.S. 1960) (deterrence rationale for exclusionary rule)
- Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (deterrence as purpose of exclusionary rule)
- Davis v. United States, 564 U.S. _ (U.S. 2011) (deterrence limited; not all illegally obtained evidence must be excluded)
- Brown v. Illinois, 422 U.S. 590 (U.S. 1975) (temporal proximity alone insufficient to justify suppression)
- Hudson v. Michigan, 547 U.S. 586 (U.S. 2006) (exclusionary rule not automatic in all unlawful conduct cases)
- Pa. Bd. of Prob. & Parole v. Scott, 524 U.S. 357 (U.S. 1998) (deterrence benefits outweighed by social costs in some contexts)
- Segura v. United States, 468 U.S. 796 (U.S. 1984) (but-for causation standard for suppression)
- United States v. Crews, 445 U.S. 463 (U.S. 1980) (causation and taint analysis in exclusionary rule)