Utah v. Strieff

Utah v. Strieff, 579 U.S. ___, 136 S. Ct. 2056 (2016), was a case in which the Supreme Court of the United States limited the scope of the Fourth Amendment's exclusionary rule.[1]

Utah v. Strieff
Argued February 22, 2016
Decided June 20, 2016
Full case nameUtah, Petitioner v. Edward Joseph Strieff, Jr.
Docket no.14-1373
Citations579 U.S. ___ (more)
136 S. Ct. 2056; 195 L. Ed. 2d 400
ArgumentOral argument
Opinion announcementOpinion announcement
Case history
PriorOn writ of certiorari to the Utah Supreme Court
Proceduralaffirming evidence admission, 286 P.3d 317 (Utah Ct. App. 2012), reversing, 357 P.3d 532 (Utah 2015)
Holding
The evidence seized incident to arrest is admissible. The officer's discovery of a valid, pre-existing, and untainted arrest warrant attenuated the connection between the unconstitutional investigatory stop and the evidence seized incident to a lawful arrest.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityThomas, joined by Roberts, Kennedy, Breyer, Alito
DissentSotomayor, joined by Ginsburg (parts I, II, III)
DissentKagan, joined by Ginsburg
Laws applied
U.S. Const. amend. IV

Background

In December 2006, South Salt Lake, Utah police began surveilling a suspected drug house.[2] Police observed Edward Strieff leaving the house although they had not observed him entering it.[3] An officer stopped Strieff on the street and conducted an investigatory detention; after asking Strieff for identification, officers discovered that Strieff had an outstanding warrant for a traffic violation.[2] Officers conducted a search incident to his arrest, and discovered that Strieff was in possession of drug paraphernalia and methamphetamine.[2] At a suppression hearing, prosecutors conceded that officers lacked reasonable suspicion to conduct the investigatory detention, but argued that the evidence seized during the detention should not be excluded because "the existence of a valid arrest warrant attenuated the connection between the unlawful stop and the discovery of the contraband."[2] The trial court admitted the evidence and Strieff then pleaded guilty, but reserved his right to appeal the suppression motion.[4]

In August 2012, the divided Utah Court of Appeals affirmed the trial court but,[5] in January 2015, the unanimous Utah Supreme Court reversed, in an opinion by Justice Thomas Rex Lee.[6]

Opinion of the Court

On June 20, 2016, the Supreme Court reversed, by a vote of 5-3. Writing for the Court, Justice Clarence Thomas, joined by Chief Justice John Roberts and Justices Anthony Kennedy, Stephen Breyer, and Samuel Alito, held that the evidence was admissible because "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 drug-related evidence on Strieff's person."[7]

Justice Sonia Sotomayor wrote a dissenting opinion in which she argued the evidence should be inadmissible and that the majority's opinion will "corrode all our civil liberties"; Justice Ruth Bader Ginsburg joined all but part IV of Justice Sotomayor's opinion.[8] Justice Elena Kagan also wrote a dissenting opinion, in which Justice Ginsburg joined in full, where she argued that the majority's ruling "creates unfortunate incentives for the police".[9]

See also

References
  1. Utah v. Strieff, No. 14–1373, 579 U.S. ___, 136 S. Ct. 2056, slip op. at 1, 6-10 (2016).
  2. Strieff, slip op. at 2.
  3. Strieff, 136 S. Ct at 2060, 2063, 2065.
  4. The Supreme Court, 2015 Term — Leading Cases, 130 Harv. L. Rev. 337 (2016).
  5. State v. Strieff, 286 P.3d 317, 2012 U.T. App. 245 (Utah Ct. App. 2012).
  6. State v. Strieff, 357 P.3d 532, 2015 U.T. 2 (Utah 2015).
  7. Strieff, slip op. at 5-9.
  8. Strieff, slip op. at 1, 12 (Sotomayor, J., dissenting).
  9. Strieff, slip op. at 1, 6 (Kagan, J., dissenting).
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