Herring v. United States

Herring v. United States Case Brief

United States Supreme Court
555 U.S. 135 (2009)

ISSUE: Should the exclusionary rule apply to evidence found during a search incident to arrest if the arrest is subsequently invalidated due to a revoked warrant on which the officers reasonably relied in arresting D?
HOLDING: No.
FACTS:
  • D went to the sheriff's dept. to get something from his impounded truck when a sheriff had a clerk check the computer system for warrants
  • An outstanding arrest warrant was found in the next county over, and D was arrested as he was driving away from the sheriff's dept.
  • When the clerk in the other county looked for the arrest warrant, she determined it had been revoked but no updated in the computer system
  • Officers had already arrested D and searched him and found a gun and meth
PROCEDURAL HISTORY:
  • Mag. Judge recommended denying the suppression motion b/c the officers had acted in a good-faith belief that the warrant was still valid
  • Dist. judge & Ct. App. agreed
REASONING:
  • No exclusionary rule: The conduct at issue here was not so objectively culpable as to require exclusion, as it was merely negligent and not reckless or deliberate
    • Any marginal deterrence is insufficient to trigger exclusion
    • Police conduct must be sufficiently deliberate in order to trigger the exclusionary rule
COMMENTS:
  • Rule: No exclusion for good-faith reliance on a negligent police error
    • But leaves open the door to exclude "systemic negligence"

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