UTAH v. EDWARD JOSEPH STRIEFF, JR.
Supreme Court of the United States, Thomas, June 20, 2016,
Search – Exclusionary Rule – Evidence recovered from a suspect search incident to a valid arrest warrant need not be excluded even where the initial detention lacked reasonable suspicion

(Dissent – Sotomayor joined by Ginsburg for parts I-III – Starts by misstating the Court’s holding, then provides legitimate points related to a constitutional violation providing the basis for a constitutional search, then on her own discusses racial impact of unconstitutional policing)
(Dissent – Kagan with Ginsburg – Discovery of an arrest warrant after an unconstitutional stop is not an “intervening circumstance,” it is a product of the unconstitutional stop)

Citing the Brown v. Illinois factors:
– Temporal Proximity
– Intervening Circumstances
– Purpose and flagrancy of misconduct

Where there was no RAS for the stop, but the officer was engaged in a legitimate investigation, stopping the suspect and conducting a warrant check did not require exclusion of evidence found after Search Incident to a lawful arrest warrant.

As the Court noted, this would not necessarily apply in the event of a “dragnet” operation intended to violate rights to search for offenders with warrants (“Were evidence of a dragnet search presented here, the application of the Brown factors could be different.”).

Then again, the Court doesn’t say that it wouldn’t apply to that situation, either.