The Exclusionary Rule in a Computer-Driven Society:
The Case of Arizona v. Evans (1995)
Introduction:
In the United States, one of the ways that the judicial branch checks the executive branch is via the exclusionary rule. Under this law, illegally obtained evidence has been inadmissible in federal criminal courts since 1914. Proponents of this rule find that it helps eliminate police misconduct and protect individual rights, while opponents believe that society is punished and criminals benefit from errors made by the police.
In the 1961 case of Mapp v. Ohio, the exclusionary rule was extended to the states. At that time, televisions had just recently become a standard in the American household and the average American had no concept of what a computer might be. However, by the 1990s, computers were as much a part of American's lives as televisions. Increasing technological skills allowed computers to be utilized by law enforcement officers as a standard part of their job.
As
technology was evolving, so were the Court's standards
regarding the controversial exclusionary rule. In a
series of cases, it recognized several exceptions. For
instance, in the 1984 case United
States v. Leon, the Court relaxed the
standard a bit to include "good faith" exceptions.
The Court held that if police believed, for instance,
that a search warrant was legal, but later found out
that it was technically flawed, the evidence obtained
in the search would still be admissible, so long as
the police had acted in "good faith".
For more information on other exceptions to the exclusionary rule, read the article "Evaluation of the Exclusionary Rule."
Directions: Read the summary of Arizona v. Evans to determine if the exclusionary rule applies to computer errors made by the police.
The Case: Arizona v. Evans
The police stopped Evans for driving the wrong way down a one-way street. After running his driver's license through their computer, the police found that there was a warrant out for his arrest. Arresting Evans, the police searched his car and found marijuana.
A search "incident to arrest" is generally understood to be constitutional. However, it turned out that the misdemeanor warrant that appeared on the police officer's computer was a mistake. The warrant had been withdrawn. At his trial, Evans argued that the computer mistake meant the search of his car was illegal. Because his car was illegally searched, he stated, the exclusionary rule should apply to the marijuana the police found.
The Supreme Court of Arizona basically agreed with Evans that the search and resulting drug charges were unconstitutional. They ruled that because the exclusionary rule is meant to deter police employees from making mistakes in the process of searching for and seizing evidence, computer records were not exempt from the rule.
In 1994, the Supreme Court of the United States decided to hear the case upon appeal from the Arizona police.
Questions to Consider:
- What is the purpose of the exclusionary rule?
- Should it apply in this case? Why or why not?
- Predict the outcome of the case.
Click here to find out the outcome in Arizona v. Evans.
Extension
Do you agree with the majority opinion or with Justice Stevens, whose comments appear in the last line of the synopsis of the dissenting opinion? Explain why.
The Supreme Court's Decision in Arizona v. Evans
In its decision, the Court reversed the decision of the Arizona Supreme Court and ruled that the search and seizure were not covered by the exclusionary rule, and therefore were constitutional. In deciding the case, the Court looked at three different things.
- They decided that the exclusionary rule was created to stop police misconduct. In this case, the Court said no misconduct had occurred.
- The Court also decided that, because there is no evidence that record keeping employees were inclined to ignore the Fourth Amendment, the computer error was probably a result of pure human error rather than an attempt to undermine the rights of individuals.
- Without evidence that extending the exclusionary rule to mistakes made by record keeping employees would change police behavior, there was no reason to believe that finding for Evans in this case would make a police officer more accurate. After all, they determined, the officer was just doing his job.
Although the majority of the Court ruled as described above, Justices Stevens and Ginsburg dissented. Justice Ginsburg thought that it was too early to rule on such a case, as technology was constantly evolving. Justice Stevens, however, believed that the search and seizure may have been unconstitutional and used the following reasoning to make his case: "the indignity of an arrest stemming from a bureaucrat's error is just as outrageous as an arrest made without probable cause."
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