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Arizona v. Evans

The Decision



The U.S. Supreme Court reversed the Arizona Court of Appeals decision, ruling in favor of the state of Arizona and allowing the evidence to be admitted into the case against Evans. Chief Justice Rehnquist wrote the Court's opinion. It noted that the exclusionary rule had been designed to curb police misconduct, and found no police misconduct in this situation. Secondly, the Court's decision took into account that office clerks are not willfully trying to violate the Fourth Amendment rights of citizens when clerical errors are made. This was taken into consideration in contrast with the potential for abuse of power in an arrest situation. Lastly, the Court noted that to allow the exclusionary rule in this case on the basis of computer error would not deter future errors by office personnel.



"The evidence in this case strongly suggests that it was a court employee's departure from established record-keeping procedures that caused the record of the respondent's arrest warrant to remain in the computer system after the warrant had been quashed," wrote Justice O'Connor in a concurring opinion. Furthermore, she concluded:

Prudently, then, the Court limits itself to the question whether a court employee's departure from such established procedures is the kind of error to which the exclusionary rule should apply. The Court holds that it is not such an error, and I agree . . . The Court's holding reaffirms that the exclusionary rule imposes significant costs on society's law enforcement interests and thus should apply only when its deterrence purposes are most efficaciously served.

Justices Stevens and Ginsburg dissented. Stevens wrote in his dissent that such an arrest due to computer error violated the dignity of a citizen as much as an arrest made without probable cause; Ginsburg noted that computer technology is still developing and that the Court should be wary of making hasty decisions in such matters.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1995 to PresentArizona v. Evans - Significance, Tempting Arrest, The Exclusionary Rule, Reagan-era Reversal, The Decision, A Growing Movement To Rescind The Exclusionary Rule