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Keywords

negligencegood faith
negligencegood faith

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Evans; U.S. v.

Facts

On July 7, 2004, Investigator Mark Anderson learned that Bennie Dean Herring had driven to the Coffee County Sheriff's Department to retrieve something from his impounded truck. Herring was arrested based on information that there was an active arrest warrant for him, which turned out to be incorrect due to a negligent bookkeeping error. A search incident to the arrest revealed illegal items, leading Herring to move to suppress the evidence on the grounds that his arrest was illegal.

On July 7, 2004, Investigator Mark Anderson learned that Bennie Dean Herring had driven to the Coffee County Sheriff's Department to retrieve something from his impounded truck. Herring was arrested based on information that there was an active arrest warrant for him, which turned out to be incorrect due to a negligent bookkeeping error.

Issue

Whether the exclusionary rule applies to evidence obtained during an arrest that was based on a mistaken belief that an outstanding warrant existed due to a negligent error in recordkeeping.

Whether the exclusionary rule applies to evidence obtained during an arrest that was based on a mistaken belief that an outstanding warrant existed due to a negligent error in recordkeeping.

Rule

The exclusionary rule does not apply if the police acted in objectively reasonable reliance on a subsequently invalidated search warrant, and suppression is not an automatic consequence of a Fourth Amendment violation.

The exclusionary rule does not apply if the police acted in objectively reasonable reliance on a subsequently invalidated search warrant, and suppression is not an automatic consequence of a Fourth Amendment violation.

Analysis

The court found that the error leading to Herring's arrest was the result of isolated negligence and was not sufficiently deliberate or reckless to warrant the exclusion of evidence. The court emphasized that the actions of the Coffee County officers were reasonable and that the exclusionary rule is designed to deter wrongful police conduct, which was not present in this case.

The court found that the error leading to Herring's arrest was the result of isolated negligence and was not sufficiently deliberate or reckless to warrant the exclusion of evidence.

Conclusion

The judgment of the Eleventh Circuit was affirmed, allowing the evidence obtained during the search to be admissible in court.

The judgment of the Eleventh Circuit was affirmed, allowing the evidence obtained during the search to be admissible in court.

Who won?

The United States prevailed in the case because the court determined that the officers acted in good faith and that the exclusionary rule did not apply due to the nature of the error.

The United States prevailed in the case because the court determined that the officers acted in good faith and that the exclusionary rule did not apply due to the nature of the error.

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