Extended Search
Generic filters
Exact matches only
Search in title
Search in content
Search in excerpt
Search in comments
Filter by Custom Post Type
Extended Search
Generic filters
Exact matches only
Search in title
Search in content
Search in excerpt
Search in comments
Filter by Custom Post Type

United States v. Sprinkle – Case Brief Summary (Federal Court)

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.