Supreme Court Ruling Regarding Evidence Collected from Searches Incident to Illegal Stops

As we all know, every citizen has certain rights that are guaranteed to them under the United States Constitution and the Bill of Rights.  One of those rights is to not be subjected to unlawful searches and seizures under the 4th Amendment.  It has been a well established doctrine of law that law enforcement officers are allowed to search a vehicle so long as the search is conducted incident to arrest.  What does that mean exactly?  That means that if you are pulled over on a traffic stop and the law enforcement officer runs your name through CODIS, NCIC, or any other electronic database and finds that you have outstanding warrants, then they can arrest you.  After you are placed into custody, those law enforcement officers are then able to search your vehicle and any contraband or illegal items that they find can be used against you.  However, in order to pull you over in the first place, the law enforcement officer would have needed "probable cause" that you had committed some type of offense against the laws of the State of Indiana, whether it be a traffic violation or the commission of a criminal offense.  If the law enforcement officer didn't have probable cause to initiate a traffic stop, then you could argue that any evidence collected after that stop could be excluded from evidence that the State would use against you.  That has been a bedrock principle of the law for a very long period of time.

However, on June 20, 2016, the United States Supreme Court changed that long-held doctrine.  In the case of Utah v. Strieff, 136 S.Ct. 2056 (2016), the Supreme Court was faced with a case where law enforcement officers had begun to conduct surveillance on a suspected drug house.  In the course of their surveillance, they observed Strieff leave the residence.  A law enforcement officer (aka "LEO") then stopped Strieff on the street for an investigatory stop after asking for his identification.  The LEO ran his name through NCIC and discovered that he had an outstanding warrant for a traffic violation.  The LEO then placed Strieff under arrest that discovered, during the search of his vehicle, incident to arrest, that he was in possession of drug paraphernalia and meth.  After a suppression hearing, the trial court admitted the evidence and Strieff ended up entering a guilty plea.  However, Strieff appealed the admission of the evidence and the Utah Supreme Court, in a unanimous opinion, reversed the ruling of the trial court.  After working its way through the appellate process, the case eventually ended up before the United States Supreme Court and in a 5-3 decision, the court held that the evidence was admissible because the discovery of a valid arrest warrant was a sufficient intervening event to break the causal chain between the unlawful stop and the discovery of the evidence on Strieff's person and in his vehicle.  

So you may ask yourself, what does this all mean?  Well the ruling in Utah v. Strieff significantly limits the protections that private citizens had from state officials and, as Justice Sotomayor states, "corrodes all our civil liberties."  Justice Kagan and Ginsburg argues that the Strieff ruling created "unfortunate incentives for the police."  This ruling allows for police officers to pull over any person without any probable cause, and, if that person is unlucky enough to have any warrant outstanding, including for a simple traffic ticket, then the LEO can search all of their person and vehicle.  It is a significant departure from the prior doctrine of law surrounding 4th Amendment protections for private citizens.

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