Yesterday, the United States Supreme Court issued a ruling allowing for the admissibility of evidence, even if said evidence was improperly seized. Under this ruling, the Court found that as long as the improper seizure was the “result of isolated negligence”, the arrest is not necessarily invalidated.
The ruling stems from a case of a man from Alabama who was arrested due to an improper notification that an arrest warrant had been issued. Upon acting upon this non-existent warrant, police discovered guns and drugs in possession of the individual, which led to his challenged conviction.
Justice Roberts, writing for the majority which also included Justices Scalia, Kennedy, Thomas and Alito, stated that, “We conclude that when police mistakes are the result of negligence such as that described here, rather than systemic error or reckless disregard of constitutional requirements," the evidence may still be admissible in court. Justice Roberts concluded that this was more of a “bookkeeping” error, and not a deliberate attempt to violate an individual’s Fourth Amendment rights.
Writing for the dissent, Justice Ginsburg, joined by Justices Stevens, Souter and Breyer, stated that, “The most 'serious impact' of the court's holding will be on innocent persons 'wrongfully arrested based on erroneous information [carelessly maintained] in a computer data base'". Instead of having motivation to ensure records are maintained correctly, the dissent argues that this ruling allows too great a leeway to encourage any need to correct any defects or problems.
The Court seems to leave the decision of the severity of the error, “bookkeeping” v. disregard of Fourth Amendment rights, up to the trial court. By allowing the trial court to determine the severity of the error, the trial court seems to have final discretion as to what can and cannot be admitted in these cases. With such discretion, it is uncertain how far this exception will go.
As an illustration of the uncertainty this ruling may cause, also reported today is the recent announcement that 945 cases in Los Angeles are being reviewed due to improper fingerprint analysis. So far, only two wrongful arrests have been found, but there is still much work to be performed. Still, the question becomes, in relation to this recent Supreme Court decision – would this fall under a “bookkeeping” error and any incriminating evidence found due to this improper fingerprinting be admissible in court? If fingerprints at a scene of a crime lead to an arrest, albeit an arrest of a different individual for an unassociated crime due to the mislabeling or misreading of fingerprints, have the rights of this unassociated individual been violated? Prior to this ruling, the answer would most certainly seem to be “yes”; however, with this ruling the answer is not so certain.
The Fourth Amendment protects individuals against unreasonable, unwarranted searches and seizures. Any evidence gained in violation of this right is excluded from being used at trial. To now say that a court has the discretion to admit evidence gained in violation of this right, due to a “bookkeeping” error, seems to be nothing more than an improper circumvention of an individual’s Constitutional rights.
For the Washington Post article discussing the Supreme Court’s decision, click here.