Arizona v. Evans

Isaac Evans drove the wrong way down a one-way Phoenix street in front of a police station in January of 1991. He was stopped by a Phoenix police officer, who asked for Evans's driver's license. Evans told the officer that it had been suspended, and the officer verified this on the computer terminal in his patrol car. That database also showed an outstanding warrant for Evans's arrest on a misdemeanor charge. The warrant was originally issued when he failed to appear in court the previous month to answer to a number of traffic tickets. Evans did eventually appear before the justice court on 19 December 1990, and a note was made in his file to "quash warrant." At that point, the clerk of the justice court should have notified the Arizona Sheriff's Office that the warrant was to be removed from the computer database; this is usually done with a phone call to the records clerk at the sheriff's office. The call was not made, and for this reason the warrant for Evans's arrest was still present in the database that the officer checked.

The officer arrested Evans; despite any protestations from a citizen that the matter of the court date had been rectified, such a cursory arrest would constitute proper police procedure. When the officer handcuffed Evans, however, he dropped a hand rolled marijuana cigarette. A search of Evans's car turned up a bag of marijuana under the seat. Evans was charged with possession, and shortly afterward the Phoenix police were informed by the justice court that the warrant should have been quashed.

Evans's lawyer requested a hearing to suppress the evidence. The trial court found for Evans, on the basis of his claim that the drugs found were the result of an unlawful search, and thus could be excluded as evidence under the "exclusionary rule." An Arizona court of appeals reversed this decision, but then when the case appeared before the Arizona Supreme Court, it was once again reversed in Evans's favor. The state of Arizona appealed to the U.S. Supreme Court, and the case was argued in December of 1994.