Utah v. Strieff

In December 2006, South Salt Lake City Police Officer Douglas Fackrell received an anonymous tip about narcotics activity at a residence. He conducted surveillance and observed Edward Strieff Jr. exit the house after a brief visit. The officer followed Strieff to a nearby parking lot and stopped him, lacking reasonable suspicion that Strieff was engaged in criminal activity. During the stop, Officer Fackrell requested identification and discovered an outstanding arrest warrant for a minor traffic violation. Upon executing the warrant, the officer searched Strieff and found a bag of methamphetamine and a pipe. Strieff was charged with possession. He moved to suppress the evidence, arguing the initial stop violated the Fourth Amendment and that the evidence constituted fruit of the poisonous tree. The trial court admitted the evidence, but the Utah Supreme Court reversed, ordering suppression. The U.S. Supreme Court agreed to hear the case to determine if the attenuation doctrine applied.

The U.S. Supreme Court ruled 5-3 in favor of Utah. The majority held that while the initial stop was unconstitutional, the evidence was admissible. Justice Clarence Thomas wrote that the discovery of the valid arrest warrant was an intervening circumstance that broke the causal chain between the illegal stop and the discovery of the evidence, applying the attenuation exception to the exclusionary rule.

Whether the discovery of a valid, pre-existing arrest warrant attenuates the connection between an unconstitutional investigatory stop and the resulting seizure of evidence, thus allowing the evidence to be admitted under the fruit of the poisonous tree doctrine.

The ruling drew widespread criticism from civil liberties groups and criminal justice reformers. Justice Sonia Sotomayor's blistering dissent warned that the decision allows police to stop people on the street almost randomly, hoping to find outstanding warrants, effectively permitting fishing expeditions that disproportionately target minority communities. The case is widely cited as a significant erosion of Fourth Amendment protections against unreasonable searches and seizures.