After receiving an anonymous tip concerning narcotics activity at a particular house, a police officer conducted surveillance. During this time, the officer saw numerous visitors arrive at the house and then depart after being there for only a few minutes. Based on these observations, the officer believed the occupants of the house were dealing drugs. When one of the visitors, later identified as Strieff, exited the house, the officer detained Strieff and asked him what he was doing at the house. During the stop, the officer requested Strieff’s identification and conducted a record check through his dispatcher. The dispatcher told the officer that Strieff had an outstanding arrest warrant for a traffic violation. The officer arrested Strieff, and during the search incident to arrest found a bag of methamphetamine and drug paraphernalia.
Even though the prosecutor conceded the officer lacked reasonable suspicion to stop Strieff, he argued the evidence seized from Strieff should not be suppressed because the existence of the valid arrest warrant attenuated the connection between the unlawful stop and the discovery of the contraband.
Whether the discovery of a valid arrest warrant was a sufficient intervening event to break the causal chain between the unlawful stop and the discovery of the drug-related evidence seized by the officer.
Yes. The Supreme Court held that the evidence seized from Strieff was admissible because the unlawful stop was sufficiently attenuated by the pre-existing arrest warrant.
The attenuation doctrine provides that evidence is admissible when the connection between unconstitutional police conduct and the evidence is remote, or has been interrupted by some intervening circumstance, so that “the interest protected by the constitutional guarantee that has been violated,” (the right to be free from unreasonable seizures) “would not be served by suppression of the evidence obtained.”
First, the Court determined the short amount of time between the unlawful stop and the search favored suppressing the evidence, as the officer discovered the contraband on Strieff’s person only minutes after the stop.
Second, the Court held the officer’s discovery of the valid arrest warrant was a critical intervening circumstance that was completely independent of the unlawful stop, which favored the State.
Finally, the Court found that the officer’s unlawful stop of Strieff was, at most, negligent, and not a flagrant act of police misconduct.
579 U.S. ___, 136 S. Ct. 2056 (2016)