State v. Fitzpatrick
Annotate this CaseAfter an agent with the Tri-Agency Safe Trails Task Force purchased quantities of marijuana from Defendants in excess of what was legal under the Medical Marijuana Act, law enforcement arrested Defendants. Officers executed search warrants for Defendants' vehicles, their residence, and the garage Defendants frequented, retrieving four times the amount of marijuana Defendants were allowed to possess as caregivers and patients under the Act. Defendants were charged with several drug-related counts. Defendants filed a joint motion to suppress and dismiss, arguing that the state engaged in "outrageous government conduct" by obtaining evidence against them in violation of their federal due process rights. The district court granted the motion because the agent broke numerous laws under the banner of law enforcement. The Supreme Court reversed, holding that because the agent's conduct stopped short of violating the fundamental fairness shocking to the universal sense of justice mandated by the due process clause, the district court erred in dismissing Defendants' charges based on the outrageous government conduct defense.
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