Arizona v. Evans
Citation and Court
514 U.S. 1 (1995) — Supreme Court of the United States
Facts
Officer stopped Evans for a traffic violation and, upon running his name through a computer, learned there was an outstanding arrest warrant. During the arrest, officers found marijuana. In fact, the arrest warrant had been quashed seventeen days earlier, but a court employee had failed to update the computer records. Evans sought suppression of the marijuana.
Issue
Does the exclusionary rule require suppression of evidence obtained incident to an arrest made in good-faith reliance on a court employee’s clerical error recorded in a court’s database?
Holding
No; the exclusionary rule does not apply when officers act in objectively reasonable reliance on court records erroneously maintained by court employees, because suppression would not deter the police misconduct the exclusionary rule is designed to prevent.
Rule / Doctrine
The good-faith exception to the exclusionary rule (established in United States v. Leon for warrant-based searches) applies when officers reasonably rely on a court’s erroneous records. The exclusionary rule deters police misconduct; where the error was made by court personnel rather than law enforcement, exclusion provides no deterrent benefit.
Significance
Arizona v. Evans extended the good-faith exception beyond police reliance on facially valid warrants (Leon) to reliance on court clerical errors. It was later extended further to police clerical errors in Herring v. United States, reinforcing a broad good-faith exception whenever police conduct was objectively reasonable.