Utah v. Strieff
Citation
579 U.S. 232 (2016)
Facts
A police officer stopped Strieff without reasonable suspicion after observing him leave a house suspected of drug activity. During the stop, the officer discovered Strieff had an outstanding arrest warrant and searched him incident to arrest, finding drugs and drug paraphernalia.
Issue
Whether evidence discovered during an unlawful investigative stop is admissible under the attenuation doctrine when an intervening outstanding arrest warrant is discovered.
Holding
The Court held the evidence admissible, finding the connection between the unlawful stop and the discovered evidence was sufficiently attenuated by the intervening arrest warrant.
Rule
Evidence discovered after an unlawful stop is not automatically suppressed if the connection between the stop and the evidence is sufficiently attenuated; an outstanding warrant is an intervening circumstance favoring attenuation under the three-factor test from Brown v. Illinois.