Arizona v. Evans
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| Arizona v. Evans | |||||||||||
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| Argued December 7, 1994 Decided March 1, 1995 |
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| Holding | |||||||||||
| The exclusionary rule does not require suppressing evidence obtained through good-faith reliance on a warrant that contains a clerical error. | |||||||||||
| Court membership | |||||||||||
| Chief Justice: William Rehnquist Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer |
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| Case opinions | |||||||||||
| Majority by: Rehnquist Joined by: O'Connor, Scalia, Kennedy, Souter, Thomas, Breyer Concurrence by: O'Connor Joined by: Souter, Breyer Concurrence by: Souter Joined by: Breyer Dissent by: Stevens Dissent by: Ginsburg Joined by: Stevens |
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| Laws applied | |||||||||||
| Fourth Amendment | |||||||||||
Arizona v. Evans, , confirmed that the exclusionary rule did not require suppression of evidence obtained through a police officer's good-faith reliance on an error made by a clerk of the court that had issued a warrant for a person's arrest.
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[edit] Facts
Isaac Evans was seen driving the wrong way on the one-way street that runs in front of the main police headquarters in Phoenix, Arizona. Officer Sargent arrested him and asked to see his driver's license. A records check revealed an outstanding warrant for Evans's arrest, and so Sargent arrested Evans. Underneath the passenger seat Sargent found a bag of marijuana. Evans was charged with possession of marijuana.
As it turned out, the arrest warrant had been quashed some 17 days before the arrest in this case, but the court in which the warrant had been quashed did not notify the police of that fact. Evans therefore argued that the arrest was illegal and the marijuana was the fruit of an unlawful search and had to be suppressed. Ultimately the Arizona Supreme Court ruled that the marijuana had to be suppressed in order to promote accuracy in records kept by both the police and the courts. Although deterrence might be the principal goal served by the exclusionary rule, the court reasoned that the exclusionary rule would deter the clerical carelessness that led to unlawful arrests.
[edit] Majority Opinion
The Fourth Amendment guards against unreasonable searches and seizures. A violation of the Fourth Amendment occurs when the illegal search takes place, not when the illegally seized evidence is used against a suspect later in court. The exclusionary rule is meant to deter future violations of the Fourth Amendment, and so it is not a freestanding right of its own.
In United States v. Leon, , 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 illegal conduct 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.
[edit] Dissenting Opinions
Justice Stevens took issue with the notion that the exclusionary rule served to deter only police misconduct. Because the Fourth Amendment constrains the power of the sovereign, the exclusionary rule -- the remedy for violating the Fourth Amendment -- should "impose[] costs on that sovereign, motivating it to train all of its personnel to avoid future violations." Nor did Justice Stevens think that the exclusionary rule was an extreme sanction, for there is nothing extreme about allowing the sovereign to profit from its "negligent misconduct."
Stevens also distinguished this case from Leon. In Leon, there had been a presumably valid warrant issued at the time of the search; in this case there was none. Furthermore, there was some police conduct involved in maintaining the database on which the officer relied to determine whether there was, in fact, a warrant out for Evans's arrest. To say that the exclusionary rule did not apply in this situation was, therefore, not entirely accurate for Justice Stevens. Moreover, Stevens observed that there was no civil remedy under section 1983 for Fourth Amendment violations that result from erroneous information in police databases, either against the individual officer or against the city that employs him. "The offense to the dignity of the citizen who is arrested, handcuffed, and searched on a public street simply because some bureaucrat has failed to maintain an accurate computer data base strikes me as... outrageous." The fact that the police happened to find Evans's marijuana as a result of inaccurate information in the database had to be weighed against the interest of law-abiding citizens.
Justice Ginsburg argued that the case was not properly before the Court because it rested on an independent and adequate ground in Arizona law -- its statute dealing with good-faith reliance on the validity of warrants. The Supreme Court's interference would therefore impede on Arizona's ability to act as a laboratory for legal innovations. The majority observed that part of the Arizona Supreme Court's decision did in fact rest on the exclusionary rule, so that the Court had jurisdiction to review the case.
