Arizona v. Evans

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Arizona v. Evans, 514 U.S. 1 (1995), was a United States Supreme Court case in which the Court instituted an exclusionary rule exception allowing evidence obtained through a warrantless search to be valid when a police record erroneously indicates the existence of an outstanding warrant due to negligent conduct of a Clerk of Court.

Contents

• 1 Background

• 2 Majority Opinion

• 3 Dissenting Opinions

• 4 See also

• 5 External links

Background

(https://en.wikipedia.org/w/index.php?title=Arizona_v._Evans&action=edit&section=1 "Edit section: Background")

On December 13, 1990, a Justice of the Peace issued a warrant for the arrest of Isaac Evans (respondent), because respondent failed to appear to answer for several traffic violations. Six days later, respondent appeared by his own volition, and the Justice of the Peace marked respondent's file for the warrant to be "quashed". Under standard court procedure, a justice court clerk informs the Sheriff's Office of a quashed warrant, however this did not take place. Thus the warrant remained on file at the Sheriff's Office even though it was no longer valid.

On January 5, 1991, respondent is observed by Phoenix police officer Bryan Sargent driving the wrong way down a one-way street near the police station. When respondent was asked for his driver's license, respondent informed Sargent that it had been suspended. This prompted Sargent to check the data terminal in his patrol car for respondent's records. The record confirmed the respondent's license was suspended, and also showed the erroneous outstanding warrant for his arrest. Based on this warrant, Sargent proceeds to arrest respondent, and in the process of arrest, respondent drops a "hand-rolled cigarette that the officers determined smelled of marijuana." Sargent then searched respondent's car and discovered a bag of marijuana, and was charged with possession. When the Phoenix Police Department notified the Justice court of the arrest, they discovered the warrant had been quashed, and informed the police.

Respondent argued that his arrest was unlawful since the warrant for his arrest had been quashed 17 days prior, and the discovery of marijuana would not have happened without said arrest. Therefore, he filed a motion to suppress due to a violation of his Fourth Amendment rights, to which the exclusionary rule is a remedy. Furthermore, he argued that "the purposes of the exclusionary rule would be served here by making the clerks for the court ... more careful about making sure that warrants are removed from the records." The trial court agreed, granting respondent's motion on the grounds that it could find no "distinction between State action, whether it happens to be the police department or not."

Upon appeal, the Arizona Court of Appeals reversed the decision on a divided vote because it "believed that the exclusionary rule [was] not intended to deter justice court employees or Sheriff's Office employees who are not directly associated with the arresting officers or the arresting officers' police department."

The Arizona Supreme Court rejected this distinction, reasoning that the exclusionary rule would force criminal records to be kept more efficiently by those who maintain them, whether police or court staff.

Majority Opinion

(https://en.wikipedia.org/w/index.php?title=Arizona_v._Evans&action=edit&section=2 "Edit section: Majority Opinion")

The Fourth Amendment guards against unreasonable searches and seizures. The exclusionary rule is not derived from the Fourth Amendment, rather it is the judicial remedy for a violation of the Fourth Amendment. Although the exclusionary rule was originally implemented as a guard for privacy rights, after _United States v. Leon _, it has been interpreted by the Supreme Court as a tool for deterring police misconduct.

In _United States v. Leon _, 468 U.S. 897 (1984), the Court had ruled that the exclusionary rule did not require the suppression of evidence seized pursuant to a search warrant that was later determined to be invalid. In Leon, the police's reliance on the validity of the search warrant was objectively reasonable; thus, excluding the evidence seized in that case would not have deterred any future misconduct on the part of the police. The exclusionary rule does not serve to deter illegal conduct on the part of judges, after all. For a similar reason, the Court in Evans ruled that the exclusionary rule should not require suppression of the evidence seized in this case.

Because court employees were responsible for the error, applying the exclusionary rule in this case would not deter future errors. First, the exclusionary rule was historically aimed at preventing police misconduct, not court clerical errors. Second, there is no evidence that court employees were motivated to "subvert the Fourth Amendment or that lawlessness among these actors requires application of the extreme sanction of exclusion." There had been testimony at a suppression hearing that the clerical error at issue in this case occurred once every three or four years—although, as Justice Ginsburg pointed out, that same witness had also admitted that the same error occurred three other times the same day. Finally, because court clerks are not actively involved in law enforcement, applying the exclusionary rule in this case would have little impact on the clerks responsible for entering data regarding outstanding warrants. Ultimately, there was no evidence that the officer acted unreasonably on the basis of the information he had at hand.

Dissenting Opinions

(https://en.wikipedia.org/w/index.php?title=Arizona_v._Evans&action=edit&section=3 "Edit section: Dissenting Opinions")

Justice Stevens took issue with the notion that the exclusionary rule served to deter only police misconduct. Because the Fourth Amendm

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