Quashed Warrant Arrest (Computer Error) In California
In Arizona v. Evans (1995) 514 U.S. 1 [131 L. Ed. 2d 34, 115 S. Ct. 1185] a court clerk evidently failed to inform a police department that a warrant for the defendant's arrest had been quashed. (At p. 5.)
As a result, the warrant appeared in the police computer.
Applying United States v. Leon (1984), 468 U.S. 897 [82 L. Ed. 2d 677] the United States Supreme Court refused to suppress the fruits of the defendant's arrest, reasoning that "if court employees were responsible for the erroneous computer record, the exclusion of evidence at trial would not sufficiently deter future errors so as to warrant such a severe sanction." (Arizona v. Evans, supra, at p. 14.)
The court explained that "there is no basis for believing that application of the exclusionary rule in these circumstances will have a significant effect on court employees responsible for informing the police that a warrant has been quashed. Because court clerks are not adjuncts to the law enforcement team engaged in the often competitive enterprise of ferreting out crime, they have no stake in the outcome of particular criminal prosecutions.
The threat of exclusion of evidence could not be expected to deter such individuals from failing to inform police officials that a warrant had been quashed." (At p. 15.)
Arizona v. Evans, supra, 514 U.S. 1 [131 L. Ed. 2d 34] was followed in People v. Downing, supra, 33 Cal. App. 4th 1641, in which a superior court clerk's entry of erroneous information into a county computer caused the police to believe the defendant was subject to a probation search clause. (At pp. 1645-1648.)
Downing concluded that police reliance on computer generated data from the judicial system was not the result of police misconduct or error, and thus evidence obtained by police acting in "objectively reasonable good faith" would not be suppressed.(At p. 1657.)