Supreme Court Cases: 1994-1995 Term
Keller, Charlene M., The FBI Law Enforcement Bulletin
During its 1994-1995 term, the U.S. Supreme Court ruled on six cases of particular interest to law enforcement officers and managers. The cases involved the scope of the exclusionary rule for errors made by court employees, the fourth amendment's "knock and announce" requirements, and the constitutionality of a Federal statute prohibiting possession of a firearm in a school zone. Other legal issues addressed by the Court included the effect of after-acquired evidence of employee wrongdoing in litigation under Federal anti-discrimination laws, the right of local government entities to appeal a denied motion for summary judgment in actions brought under 42 U.S.C. [section] 1983 for alleged unconstitutional police conduct, and the right of law enforcement officers to appeal immediately a court's denial of qualified immunity in cases involving a factual dispute. This article summarizes these six cases and their impact on law enforcement.
Arizona v. Evans, 115 S. Ct. 1185 (1995)
In Evans, the Supreme Court held that the fourth amendment's exclusionary rule does not require suppression of evidence gained during arrests made on the basis of computer errors by clerical court employees. In this case, a Phoenix police officer arrested the defendant during a routine traffic stop when the patrol car's computer data terminal showed an outstanding misdemeanor warrant for his arrest. When a subsequent search of the defendant's car revealed a bag of marijuana, the police officer charged him with possession. The defendant moved to suppress the marijuana as fruit of an unlawful arrest because the misdemeanor warrant had been quashed before his arrest but court employees had erroneously left the warrant in the computer data base.
The Arizona Supreme Court granted the motion to suppress the marijuana, reasoning that the application of the exclusionary rule would serve to improve the efficiency of recordkeepers in the criminal justice system. The U.S. Supreme Court reversed, concluding that the exclusion of evidence was not required because court personnel were responsible for the computer's inaccurate records.
The Court reaffirmed its decision in United States v. Leon, 468 U.S. 897 (1984), in which the Court held that exclusion is not required where officers act in "objectively reasonable reliance" on a properly issued search warrant that later is ruled invalid. The Court in Evans created an additional exception to the exclusionary rule for the errors of court employees, using the Leon rationale that the exclusionary rule is designed to deter police misconduct, not mistakes by court employees. The Court concluded that application of the exclusionary rule would have no significant effect on court employees responsible for informing police that a warrant has been quashed because court clerks are not members of the law enforcement team and therefore have no stake in the outcome of particular criminal prosecutions.
Likewise, applying the exclusionary rule for the clerk's mistake would not alter the arresting officer's behavior. Unfortunately, the Court did not address in this decision whether the exclusionary rule would apply if a police employee made the computer error.
Evans, however, does not relieve officers of their responsibility to assess the reliability and potential for error of information obtained from a computer system. In this regard, a concurring opinion in Evans suggested exclusion would be required if officers blindly rely on information in their data system, regardless of their knowing the information is inaccurate or that the system is not generally reliable.
Wilson v. Arkansas, 115 S. Ct. 1914 (1995)
The Court in Wilson ruled that "knock and announce" requirements are part of the reasonableness inquiry under the fourth amendment. In evaluating the scope of the constitutional right to be secure in one's home, the Court adopted the common law protection of announcing one's presence and authority before entering a dwelling as a factor to be considered in assessing the reasonableness of a search. …