Utah v. Strieff
136 S. Ct. 2056
| SCOTUS | 2016Background
- Police received an anonymous tip about drug activity at a residence; Detective Fackrell surveilled the house and observed short visits, including respondent Edward Strieff leaving the home.
- Officer Fackrell stopped and detained Strieff in a nearby store parking lot, asked questions, and requested ID.
- The officer ran Strieff’s identification through dispatch, learned of a pre-existing arrest warrant for a traffic violation, arrested Strieff, and searched him incident to arrest, discovering methamphetamine and paraphernalia.
- State charged Strieff; he moved to suppress the evidence as fruit of an unlawful investigatory stop. The State conceded the stop lacked reasonable suspicion but argued attenuation via the discovered warrant.
- Utah trial court and Utah Court of Appeals admitted the evidence; Utah Supreme Court reversed and ordered suppression. The U.S. Supreme Court granted certiorari and reversed, holding the warrant attenuated the taint from the unlawful stop.
Issues
| Issue | Strieff's Argument | State's Argument | Held |
|---|---|---|---|
| Whether the attenuation doctrine can apply when an unconstitutional stop leads to discovery of a valid, pre-existing arrest warrant and then to evidence seized incident to arrest | The warrant did not break the causal chain because the officer exploited the illegal stop to run the warrant check; suppression required | Discovery of a valid, independent warrant is a critical intervening circumstance that severs the causal chain and makes the evidence admissible | The Court held the warrant discovery attenuated the connection; evidence admissible |
| How to apply Brown v. Illinois factors (temporal proximity, intervening circumstances, flagrancy of misconduct) to these facts | Short time between stop and search + purposeful fishing weigh for suppression; foreseeability of warrant-checks means the warrant was not an intervening cause | Although temporal proximity favored suppression, the valid pre-existing warrant and lack of flagrant misconduct outweighed that factor | Court found temporal proximity favored suppression but was outweighed by intervening warrant and lack of flagrant misconduct; admissible |
| Whether officer’s subjective purpose or negligence affects attenuation analysis | The officer’s investigatory purpose renders the stop purposeful and in need of deterrence; exclusion necessary | Officer acted negligently or in good faith; misconduct not flagrant so exclusion not required | Court treated misconduct as nonflagrant (at most negligent), reducing exclusionary-rule deterrence value |
| Whether admitting evidence will encourage widespread dragnet stops via routine warrant checks | Admitting evidence will incentivize fishing expeditions and disproportionately harm communities with many outstanding warrants | Routine warrant checks are common, but dragnet behavior would be checked by civil liability and Brown factors in other cases | Court rejected slippery‑slope concern as speculative and pointed to civil remedies; left scope to Brown-factor analysis |
Key Cases Cited
- Mapp v. Ohio, 367 U.S. 643 (1961) (incorporation of exclusionary rule to states)
- Brown v. Illinois, 422 U.S. 590 (1975) (three‑factor attenuation test: temporal proximity, intervening circumstances, flagrancy)
- Segura v. United States, 468 U.S. 796 (1984) (warrant may render later seizure independent or attenuated)
- Nix v. Williams, 467 U.S. 431 (1984) (inevitable discovery exception)
- United States v. Leon, 468 U.S. 897 (1984) (good‑faith exception to exclusionary rule; warrants as judicial mandates)
- Hudson v. Michigan, 547 U.S. 586 (2006) (exclusionary rule applied only when deterrence benefits outweigh social costs)
- Arizona v. Gant, 556 U.S. 332 (2009) (scope of search incident to arrest)
- Davis v. United States, 564 U.S. 229 (2011) (exclusionary rule’s deterrence focus; suppression only when benefits outweigh costs)
- Kaupp v. Texas, 538 U.S. 626 (2003) (temporal proximity: ‘‘substantial time’’ may favor attenuation)
- Wong Sun v. United States, 371 U.S. 471 (1963) (fruit of the poisonous tree and attenuation principles)
- Terry v. Ohio, 392 U.S. 1 (1968) (reasonable‑suspicion standard for investigatory stops)
- Weeks v. United States, 232 U.S. 383 (1914) (early articulation of exclusionary principle)
- Rodriguez v. United States, 575 U.S. 348 (2015) (limits on prolonging a stop; officer safety justification described as minimally burdensome)
- Herring v. United States, 555 U.S. 135 (2009) (attenuation/attenuation‑style balancing; negligent recordkeeping may not require suppression)