Utah v. Strieff

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.