State v. TatroAnnotate this Case
The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court suppressing derived from a search because it found that the search resulted directly from a police officer's unconstitutional seizure of Defendant, holding that this case must be remanded to the district court for further findings of fact.
Applying the attenuation doctrine factors set forth by the United States Supreme Court, the district court suppressed the evidence at issue. The court of appeals reversed the district court's ultimate decision, finding that an intervening circumstance attenuated the taint of the unlawful seizure and thus did not invalidate the later search. The Supreme Court reversed, holding (1) the district court erred in failing to consider the officer's discovery of an arrest warrant as a circumstance that intervened between the officer's illegal detention of Defendant and his search of her purse after arresting her; and (2) because there remained unanswered questions of fact, the case is remanded for the district court to make the appropriate findings of fact under the correct legal standard.