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Arizona v. Evans, 514 U.S. 1, 115 S.Ct. 1185, 131 L.Ed.2d 34, 63 USLW 4179

Facts

Respondent Isaac Evans was arrested by Phoenix police during a traffic stop based on a computer record indicating an outstanding misdemeanor warrant. However, the warrant had been quashed 17 days prior to his arrest. After the arrest, a search of his car revealed marijuana, leading to charges of possession. Evans moved to suppress the evidence, arguing that the arrest was unlawful due to the quashed warrant. The trial court initially granted the motion, but the Court of Appeals reversed this decision, leading to the Supreme Court's involvement.

In January 1991, Phoenix police officer Bryan Sargent observed respondent Isaac Evans driving the wrong way on a one-way street in front of the police station. The officer stopped respondent and asked to see his driver's license. After respondent told him that his license had been suspended, the officer entered respondent's name into a computer data terminal located in his patrol car. The computer inquiry confirmed that respondent's license had been suspended and also indicated that there was an outstanding misdemeanor warrant for his arrest.

Issue

Whether evidence seized in violation of the Fourth Amendment by an officer who acted in reliance on a police record indicating the existence of an outstanding arrest warrant must be suppressed due to the exclusionary rule, regardless of the source of the error.

The Supreme Court of Arizona held that the exclusionary rule required suppression of evidence even if the erroneous information resulted from an error committed by an employee of the office of the Clerk of Court.

Rule

The exclusionary rule does not require suppression of evidence seized in violation of the Fourth Amendment where the erroneous information resulted from clerical errors of court employees, as the rule is designed to deter police misconduct rather than mistakes by court personnel.

The exclusionary rule does not require suppression of evidence seized in violation of the Fourth Amendment where the erroneous information resulted from clerical errors of court employees.

Analysis

The Supreme Court applied the reasoning from previous cases, determining that the exclusionary rule was not intended to deter clerical errors made by court employees. The court noted that the officer acted reasonably in relying on the computer record and that there was no evidence suggesting that court employees would ignore or subvert the Fourth Amendment. Therefore, the court concluded that excluding the evidence would not serve the rule's deterrent purpose.

The Arizona Supreme Court determined that it could not support the distinction drawn … between clerical errors committed by law enforcement personnel and similar mistakes by court employees.

Conclusion

The Supreme Court reversed the Arizona Supreme Court's decision, holding that the exclusionary rule does not apply in this case, and remanded for further proceedings consistent with its opinion.

The judgment of the Supreme Court of Arizona is therefore reversed, and the case is remanded to that court for proceedings not inconsistent with this opinion.

Who won?

The State of Arizona prevailed in the case, as the Supreme Court ruled that the exclusionary rule did not apply to the evidence obtained due to clerical errors by court employees.

The Arizona Supreme Court reversed. The court rejected the distinction between clerical errors committed by law enforcement personnel and similar mistakes by court employees and predicted that the exclusionary rule's application would serve to improve the efficiency of criminal justice system recordkeepers.

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