Utah v. Strieff

Utah v. Strieff
Supreme Court of the United States
Argued February 22, 2016 Decided June 20, 2016
Full case name	Utah, Petitioner v. Edward Joseph Strieff, Jr.
Docket nos.	14–1373
Citations	579 U.S. ___ (more) 136 S. Ct. 2056, 195 L. Ed. 2d 400
Argument	Oral argument
Opinion announcement	Opinion announcement
Prior history	On writ of certiorari to the Utah Supreme Court
Procedural history	affirming evidence admission, 286 P.3d 317 (Utah Ct. App. 2012), reversing, 357 P.3d 532 (Utah 2015)
Holding
The evidence seized incident to arrest is admissible. The officer's discovery of a valid, pre-existing, and untainted arrest warrant attenuated the connection between the unconstitutional investigatory stop and the evidence seized incident to a lawful arrest.
Court membership
Chief Justice John G. Roberts Associate Justices Anthony Kennedy Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito Sonia Sotomayor · Elena Kagan
Case opinions
Majority	Thomas, joined by Roberts, Kennedy, Breyer, Alito
Dissent	Sotomayor, joined by Ginsburg (parts I, II, III)
Dissent	Kagan, joined by Ginsburg
Laws applied
U.S. Const. amend. IV

Utah v. Strieff, 579 U.S. ___, 136 S. Ct. 2056 (2016), was a case in which the Supreme Court of the United States limited the scope of the Fourth Amendment's exclusionary rule.

In December 2006, South Salt Lake, Utah police began surveilling a suspected drug house. Police observed Edward Strieff leaving the house although they had not observed him entering it. An officer stopped Strieff on the street and conducted an investigatory detention; after asking Strieff for identification, officers discovered that Strieff had an outstanding warrant for a traffic violation. Officers conducted a search incident to his arrest, and discovered that Strieff was in possession of drug paraphernalia and methamphetamine. At a suppression hearing, prosecutors conceded that officers lacked reasonable suspicion to conduct the investigatory detention, but argued that the evidence seized during the detention should not be excluded because "the existence of a valid arrest warrant attenuated the connection between the unlawful stop and the discovery of the contraband." The trial court admitted the evidence and Strieff then pleaded guilty, but reserved his right to appeal the suppression motion.

In August 2012, the divided Utah Court of Appeals affirmed the trial court but, in January 2015, the unanimous Utah Supreme Court reversed, in an opinion by Justice Thomas Rex Lee.

On June 20, 2016, the Supreme Court reversed, by a vote of 5-3. Writing for the Court, Justice Clarence Thomas, joined by Chief Justice John Roberts and Justices Anthony Kennedy, Stephen Breyer, and Samuel Alito, 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 drug-related evidence on Strieff's person."