State v Strieff

Strieff was detained without reasonable suspicion. The officer learned that Strieff had an outstanding warrant, arrested him and searched him discovering drugs. Strieff moved to exclude eth evidence. The district court denied the motion ruling the arrest warrant satisfied the attenuation exception. A split panel of the Court of Appeals affirmed. The Court unanimously reversed. It held attenuation, as best understood in United States Supreme Court decisions, applies only when a free will act of a defendant, such as a voluntary confession, beaks the causal chain and makes suppression inappropriate. Here, the arrest warrant was not a free will act. Thus, the Court held this case is controlled by the separate inevitable discovery rule. As there is nothing inevitable that Strieff would have been arrested at some point in the future with the same drugs on his person, that exception does not apply either. The Court ordered the motion to suppress be granted. It also noted that it was adopting a rule different form the majority and minority approaches of state appellate courts and federal circuits. It reasoned that his is required as attenuation and inevitable discovery are different rules driven by different concerns and favoring arrest pursuant to warrant over all other lawful police actions is inappropriate. The Court finally noted it did the best it could to determine what the United States Supreme Court means in its decision.