United States v. Sprinkle
In United States v. Sprinkle, 106 F.3d 613 (4th Cir. 1997), the Fourth Circuit has held that the commission of a new crime purges the taint of an unlawful search or seizure.
law enforcement officers effected an unlawful vehicle stop and the defendant ran from the police, pulled a gun, and fired at them.
The defendant was charged with being a felon in possession of a firearm.
At trial, the defendant filed a motion to suppress the gun on the grounds that it was seized illegally due to a lack of reasonable suspicion for the stop. Id. at 616.
The Fourth Circuit held that the officers did lack reasonable suspicion for the stop, but that the defendant committed a new crime when he pointed the gun and fired at the officers, and thus, the seizure of the gun was lawful and admissible. Id. at 619-620.
The Circuit reasoned that "a new and distinct crime, even if triggered by an illegal stop, is a sufficient intervening event to provide independent grounds for arrest." Id. at 619.