Arizona v. Evans

Evans's case hinged on the Fourth Amendment, which states that:

The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.

The exclusionary rule holds that evidence obtained as the result of an illegal search cannot be admitted in court. At the trial level, a formal arrest warrant obtained from a magistrate can be invalidated if it can be shown that the police lacked probable cause in obtaining it. Any evidence obtained in that search is not allowable in court for use in prosecuting the respondent. The use of the exclusionary rule in state courts, especially in regard to criminal cases, dates back to the U.S. Supreme Court's decision in Mapp v. Ohio (1961).

The Arizona Court of Appeals reversed the first court's decision in Evans and moved to allow the marijuana into the case against Evans. It did so after deciding that the exclusionary rule did not apply in this situation, since "the purpose of the exclusionary rule was to deter police officers," and "was not intended to deter justice court employees" or other support staff.

But the Arizona Supreme Court reversed that decision. Its justices spoke of a clear distinction between police officers and office support staff. The state court decided in Evans's favor, declaring that the application of the exclusionary rule in this case would make clerks and other support personnel more diligent about record-keeping.