Utahv.Strieff
Police officers investigating an anonymous tip stopped Edward Strieff without reasonable suspicion, learned during the stop that he had an outstanding arrest warrant, arrested him, and found drugs during a search incident to that arrest. The Supreme Court of the United States held that the discovery of the valid warrant sufficiently attenuated the connection between the unconstitutional stop and the later seizure. Applying the attenuation analysis, the majority treated the warrant as an intervening circumstance and the officer’s conduct as not sufficiently purposeful or flagrant to require exclusion. The Court therefore reversed the Utah Supreme Court and held the evidence admissible. Justice Sotomayor dissented, joined in relevant parts by Justice Ginsburg, warning that the decision weakened the protection against suspicionless stops and placed many people at risk of searches based on outstanding warrants. Justice Kagan also dissented, explaining that the exclusionary rule must account for the causal role of the unlawful stop and the incentive structure facing police.
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