State v. KerrAnnotate this Case
The circuit court erred in granting Defendant’s motion to suppress evidence discovered during a search incident to arrest on the basis that “‘judicial integrity’ was vital enough to justify exclusion of evidence when the issuing court’s arrest warrant was invalid ab initio.”
Defendant was charged with one count of possession of methamphetamine. Defendant filed a motion to suppress, arguing that, while a warrant had been issued and law enforcement did not engage in misconduct in executing the warrant, his constitutional rights were violated because the warrant violated his due process rights. The reviewing court agreed and granted the motion to suppress. The Supreme Court reversed, holding (1) suppression of evidence discovered during the search incident to arrest was not appropriate because the sole purpose of the exclusionary rule is to deter police misconduct, and there was no police misconduct in this case; and (2) neither judicial integrity nor judicial error is a standalone basis for suppression under the exclusionary rule.