Facts
Douglas Fackrell, a narcotics detective, was acting on an anonymous tip regarding suspected drug dealership on a residence at South Lake City. He was growing suspicious owing to the number of people who visited the house within a week of his investigation. Officer Fackrell detained the respondent, Edward Strieff, a few minutes after leaving the residence. After introducing himself and questioning Strieff as to what he was doing at the home, the officer checked Strieff’s identification details with a police dispatcher (Utah, Petitioner v. Edward Joseph Strieff Jr., 2016). The search established that Strieff had violated traffic rules, an act for which he had an outstanding arrest warrant. Upon arresting and searching Strieff, Officer Fackrell found drug paraphernalia and methamphetamine.
Procedural History
Strieff decided to squash the evidence because Officer Fackrell collected them from an unlawful investigatory stop. The Utah Court of Appeals affirmed that the evidence was admissible. While delivering the opinion of the court, Justice Thomas noted that discovering an arrest warrant attenuated the relationship between the unlawful detaining and seizure of evidence from the respondent to arrest. Therefore, the court held the evidence was admissible. According to Strieff, the action of Fackrell in stopping him was flagrant and purposeful, because he was focused on gathering evidence of suspected wrongdoing (Utah, Petitioner v. Edward Joseph Strieff Jr., 2016). However, the court held that Officer Fackrell wanted to learn more about the house alleged to be hosting suspected drug dealers.
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Issues
The Fourth Amendment holds that evidence seized from unconstitutional searches may not be adduced in a court of law. Justice Sotomayor argued that Fackrell broke the Fourth Amendment by detaining Strieff and searching his license without evidence that he had committed any crime. Justice Sotomayor refers to the 1961 case of Mapp v. Ohio, where the judge employed the exclusionary rule in his ruling. In a situation where a police officer unlawfully discovers evidence of unconstitutional conduct by a civilian, a criminal trial must exclude evidence that was illegally acquired. The rule of exclusion ensures that courts steer clear of illegal invasions of citizens’ lawful rights.
Utah Court of Appeals had indicated that the acts of Officer Fackrell were isolated to this case, and not a part of recurrent police misconduct. Sotomayor disagreed, noting that outstanding warrants are common in the United States. Within only four years, officers in Newark, New Jersey, stopped more than 52,000 pedestrians, 39,308 of which were subjected to warrant checks (Utah, Petitioner v. Edward Joseph Strieff Jr., 2016). Justice Kagan acknowledges that there is a question of whether courts should admit evidence seized by officers who discover that an individual has an outstanding arrest warrant immediately after stopping them. According to Kagan, the question has no impact on decisions made within constitutional confines, hence his dissent.
Holding
Justice Sotomayor gave a dissenting opinion because Officer Fackrell violated the Fourth Amendment rights of Strieff. The Fourth Amendment protects people’s right to be safe in their houses, effects, papers, and personal levels. Justice Kagan also gave a dissenting opinion to the decision of the Utah Court of Appeals. Kagan agrees with Sotomayor that a police officer violates the Fourth Amendment if they stop an individual walking freely, without reasonable suspicion. Seized evidence should be suppressed only when benefits to society outweigh the costs. Preventing the use of illegally acquired evidence helps courts in minimizing the habit of law enforcement officers to flout the Fourth Amendment’s regulations.
Kagan recognizes that the majority is wrong to understate the problems that come with violation of Fourth Amendment rules. Indeed, Officer Fackrell admits that he stopped Strieff to find out what he had been doing at the residence. Additionally, he realized that he found no reason to suspect Strieff, except for the fact that he had come from the building that was a target in his investigations (Utah, Petitioner v. Edward Joseph Strieff Jr., 2016). Therefore, if a police officer unlawfully searches individuals and discovers evidence of illegal activities, such evidence cannot be admitted in a court of law.
References
Utah, Petitioner v. Edward Joseph Strieff Jr., 14 U.S 1373 (2016).
