## Facts

- A Phoenix police officer stopped Isaac Evans for driving the wrong way on a one-way street and learned Evans said his license was suspended.
- A computer check showed Evans’s license was suspended and reported an outstanding misdemeanor arrest warrant.
- Relying on the reported warrant, the officer arrested Evans.
- During the arrest, Evans dropped a hand-rolled cigarette that smelled of marijuana, and a search of the car revealed marijuana.
- The reported warrant had been quashed 17 days earlier after Evans appeared in court; a court clerk failed to notify the sheriff’s office to remove the warrant from the database.
- Evans moved to suppress the marijuana as the product of an unlawful arrest based on an invalid warrant entry.

## Issues

1. Whether the Supreme Court had jurisdiction when the state court’s decision appeared to rest on federal law without a clear statement of an independent state ground.
2. Whether the Fourth Amendment exclusionary rule requires suppression of evidence seized incident to an arrest made in reasonable reliance on a computer record of a warrant that was erroneous due to a court employee’s clerical mistake.

## Decision

- The Court held it had jurisdiction under the presumption applied when a state decision appears to rest primarily on federal law and lacks a clear statement of independent state grounds.
- The Court reversed the state supreme court and held, by a 7–2 vote, that the exclusionary rule did not require suppression.
- The Court reasoned that the officer acted objectively reasonably in relying on the computer record and that the error was attributable to court personnel rather than police misconduct.
- The Court concluded that suppressing evidence for court-clerk mistakes would yield little deterrent benefit compared to the social costs of excluding reliable evidence.

## Legal Principles

- The exclusionary rule is a judicially created remedy aimed primarily at deterring unlawful police conduct, not a personal constitutional right.
- Suppression is appropriate only when the deterrent benefits of exclusion outweigh its social costs.
- When an officer acts objectively reasonably in relying on a record indicating an outstanding warrant, evidence need not be suppressed if the record is erroneous because of clerical error by court employees.
- Under the jurisdictional presumption applied to state decisions interwoven with federal law, the Supreme Court will review absent a clear statement that the judgment rests on an adequate and independent state ground.

## Conclusion

The Court held that the exclusionary rule does not bar evidence obtained incident to an arrest made in reasonable reliance on a warrant record that remained in a database solely because court personnel failed to update it after the warrant was quashed, and it reaffirmed that state courts must clearly state independent state grounds to avoid federal review.


Arizona v. Evans, 514 U.S. 1 (1995)