Castle v. State
In Castle v. State, 999 P.2d 169 (Alaska App. 2000), the defendant walked away from a police officer after the officer unjustifiably ordered the defendant to remain at the scene of a traffic stop and wait to be interviewed.
The officer chased Castle, and he eventually caught Castle and subdued him. A subsequent search of Castle's pockets yielded several small bags of cocaine. (Castle, 999 P.2d at 170-71.)
In Castle, the State argued that even if the police initially had no justification for ordering Castle to remain at the scene and be interviewed, Castle's later actions gave the police grounds to arrest him -- because, while Castle was fleeing from the police, he violated municipal law by running in the middle of a street.
The Court held that even if this was true, the exclusionary rule precluded the State from relying on Castle's violation of municipal law as a ground for arresting him -- because Castle's action was a direct response to the officer's attempt to unlawfully detain Castle.
In Castle v. State, a police officer attempted to conduct an investigative stop of the defendant. Fleeing from the officer, the defendant committed a minor offense: running in the middle of the street, a violation of a municipal ordinance regulating pedestrian traffic.
The Court held that the officer's initial effort to conduct an investigative stop had been illegal. The remaining question was whether the State could rely on Castle's ensuing violation of the municipal ordinance to justify the ultimate stop.
The Court said no; the State could not rely on Castle's act of running in the street to justify the stop because Castle's violation of the pedestrian ordinance was "the direct result of the officer's unjustified attempt to seize Castle", and because "the policy of the exclusionary rule would be undermined if we allowed Castle's conduct to form the justification for his ensuing arrest".