State v. Daniel
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The Supreme Court reversed the judgment of the trial court granting Defendant’s motion to suppress a blood sample drawn from Defendant pursuant to a search warrant because the arresting officer failed to leave a copy of the warrant with Defendant, holding that, under the facts and circumstances of this case, a good-faith exception should be applied to Tenn. R. Crim. P. 41’s exclusionary rule.
The trial court granted Defendant’s motion to suppress the evidence obtained pursuant to the warrant on the basis of the exclusionary rule set out in Rule 41. The Court of Criminal Appeals affirmed. The Supreme Court reversed and remanded this matter to the trial court for further proceedings, holding that, given the specific facts of this case, a good-faith exception to Rule 41’s technical requirement that the officer executing a search warrant leave a copy of the warrant with the person searched should apply to this case.
Court Description:
Authoring Judge: Chief Justice Jeffrey S. Bivins
Trial Court Judge: Judge Deanna B. Johnson
We granted permission to appeal in this case in order to determine whether the exclusionary rule should be applied to a blood sample drawn from an individual pursuant to a search warrant because the arresting officer failed to leave a copy of the warrant with the individual. The Defendant, Angela Faye Daniel, was arrested for driving under the influence. The arresting officer obtained a search warrant and transported the Defendant to a medical facility for a blood draw. The officer failed to give the Defendant a copy of the search warrant. The trial court granted the Defendant s motion to suppress the evidence obtained pursuant to the warrant on the basis of the exclusionary rule set forth in Tennessee Rule of Criminal Procedure 41. The State sought and was granted an interlocutory appeal, and the Court of Criminal Appeals affirmed. We hold that, under the facts and circumstances of this case, a good-faith exception should be applied to Rule 41 s exclusionary rule. Accordingly, we reverse the judgment below and remand this matter to the trial court for further proceedings.
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