U.S. Supreme Court Opinion Breakdown – Utah v Strieff
The U.S. Supreme Court in Utah v Strieff upset many individuals with its opinion because the court essentially allowed for illegally obtained evidence to be used to convict an individual due to the attenuation doctrine. The issue before the Court, in Utah v Strieff, was based upon facts as follows: an officer was investigation a drug house for numerous days, and the defendant in the case was exiting said house, he was stopped by the officer, questioned about where he was going, where he had been, and what he was doing. Subsequently, the officer had the individual ran through the department’s computer system, and upon completing the search an outstanding warrant for an unpaid ticket appeared. The officer then arrested the individual on the warrant, and incident to that arrest performed a warrantless search of the defendant, finding illegal contraband on his person.
The Court, in Utah v Strieff, examined this case using a legal doctrine that that allows for illegally or improperly obtained evidence to be admissible in a trial if there was some act or event that would essentially allow for the evidence to become legally or properly obtained. This means the event or act trumps the illegality, refreshing the evidence and allowing it to now be admissible in trial. Prior to the opinion in Utah v Strieff, courts generally only looked to two events capable of trumping illegality, which was consent to search or by confession. The U.S. Supreme Court, however, explained that the outstanding warrant was an event that can trump the prior illegality committed by the Officer because essentially the warrant refreshed the officer’s ability to act, arrest or search the individual defendant. Moreover, the court indicated that it was separate from the illegal actions of the officer performing his job, which is to arrest or search when an individual has an open warrant. This means the illegal conduct, stop and confrontation by the officer becomes irrelevant when attempting to suppress or dismiss evidence later obtained.
The issue in Utah v Strieff, surrounded around whether there was illegality performed by the officer. The reason for this is due to the fact that if the defendant was able to show that the officer illegality or improperly stopped the individual then he has the ability to ask the court to dismiss or suppress all evidence obtained after the improper or illegal act. The court in Utah v Strieff, essentially said that “yes, the officer acted improperly when first stopping and confronting the Defendant, yet upon learning of the warrant, the actions of the officer are appropriate and all evidence is admissible.” This opens up numerous arguments for the State, Township, City or Municipality attempting to prosecute individual defendants. Know the law, maintain your rights, and lawyer-up. Josh Jones is a criminal defense attorney, handling criminal and traffic cases and cases like Utah v Strieff for defendants throughout Michigan.
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