Utah v. Strieff
United States Supreme Court
136 S.Ct. 2056 (2016)
While surveilling a house suspected of drug activity, officer Douglas Fackrell stopped Edward Strieff (defendant) after he left, not based on any individualized suspicion of Strieff himself but solely to question visitors about the house's activities; a routine records check turned up an outstanding warrant for a minor traffic offense, and Fackrell arrested Strieff on that warrant and, in a search incident to arrest, found illegal drugs. The trial court admitted the drugs despite Strieff's argument they were fruit of an unconstitutional stop, and the Utah Court of Appeals affirmed his conviction, but the Utah Supreme Court reversed; the state sought Supreme Court review.
Whether unconstitutionally seized evidence is admissible if lack of flagrant impropriety, lack of temporal proximity, or an intervening circumstance attenuates the chain between police misconduct and the seizure.