Sara Gilbert

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In Arizona v. Evans, the United States Supreme Court considered whether the exclusionary rule requires suppression of evidence seized incident to an arrest, when the arrest resulted from inaccurate computer data created by court personnel. In January 1991, police arrested Isaac Evans during a routine traffic stop because the patrol car's computer indicated he was the subject of an outstanding misdemeanor warrant. While being handcuffed, Evans dropped a marijuana cigarette. A subsequent search of the vehicle revealed a bag of marijuana hidden under the passenger seat, and Evans was charged with possession. Upon notifying the justice court of the arrest, the officers discovered the misdemeanor warrant had been quashed seventeen days earlier. Evans moved to suppress the evidence, alleging the seizure resulted from an illegal search incident to an unlawful good-faith exception to the exclusionary rule did not apply. The arrest, Evans alleged, was not caused by judicial error, but by police error. The trial court granted the motion to suppress, finding the State was at fault for failing to quash the warrant. The court made no factual finding as to whether the sheriff's office or the justice court was responsible for the error. Instead, the court found no "distinction between State action, whether it happens to be the police department or not." The Arizona Court of Appeals reversed the trial court's ruling. According to the court of appeals, the exclusionary rule was not intended to deter errors by justice court employees or sheriff's office employees who were not directly associated with the arresting officers or their police department. The court reasoned that the computer clerical error was outside the control of the arresting officers' police department. Therefore, the threat of exclusion would not deter the justice court employees or sheriff's office employees from making similar mistakes in the future. The Arizona Supreme Court rejected the distinction between clerical errors committed by law enforcement personnel and similar errors committed by court employees and therefore reversed. The court found that regardless of who erred, the exclusionary rule was "useful" and "proper" when negligent recordkeeping resulted in an unlawful arrest. The United States Supreme Court granted certiorari and reversed the Arizona Supreme Court. The Court held the exclusionary rule does not require suppression of evidence when police relied in good-faith upon misinformation caused by computer clerical error.