The defendant was stopped for a routine traffic violation. During this encounter, the officer learned of an outstanding warrant for the defendant’s arrest. The officer arrested the defendant and conducted a search of the automobile incident to that arrest, where he found marijuana. He charged the defendant with possession of a controlled substance. Later, the government learned that a court clerk should have previously removed the arrest warrant from the computer database. The defendant moved to suppress the marijuana as it was the fruit of an unlawful arrest.
Whether the fruit of the poisonous tree doctrine is applicable when the officer acted in good faith reliance on a computer warrant database?
No. The fruit of the poisonous tree doctrine is designed to deter the unreasonable actions of law enforcement officers.
Under the framework of the good faith exception to the exclusionary rule established by United States v. Leon, the rule does not require the suppression of evidence seized because of clerical errors of court employees. Exclusion is appropriate only if such action serves the remedial objectives of the rule. The exclusionary rule is designed to deter police misconduct, not mistakes of court employees. In the case at hand, there was no unreasonable or illegal police activity that needed to be deterred.
514 U.S. 1, 115 S. Ct. 1185 (1995)