In Herring v. United States (2009) 555 U.S. 135, officers in one county arrested the defendant based on a warrant listed in a neighboring county's computer database. The defendant was searched incident to arrest, and the officers found drugs and a gun. (Herring, supra, 555 U.S. at p. 137.) It was subsequently discovered that the warrant had been recalled months earlier, although that information was never entered into the county's database. (Id. at pp. 137-138.) The defendant was indicted on federal gun and drug possession charges and moved to suppress the evidence, arguing his arrest had been illegal. (Id. at p. 138.) His suppression motion was denied. (Ibid.) The Supreme Court assessed the culpability of the police and the efficacy of excluding the evidence in deterring future police misconduct, concluding: "To trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningfully deter it, and sufficiently culpable that such deterrence is worth the price paid by the justice system. As laid out in our cases, the exclusionary rule serves to deter deliberate, reckless, or grossly negligent conduct, or in some circumstances recurring or systemic negligence." (Id. at p. 144.) However, where "police mistakes are the result of negligence . . . rather than systemic error or reckless disregard of constitutional requirements, any marginal deterrence does not 'pay its way.' In such a case, the criminal should not 'go free because the constable has blundered.' " (Id. at pp. 147-148.) The Herring court emphasized, however, that to claim the benefits of the good faith exception, the police must have acted "'in objectively reasonable reliance"' on factually incorrect information or subsequently invalidated warrants or statutes. (Id. at pp. 142, 146.) In Herring v. United States, the court confronted the question of whether evidence should be suppressed where police personnel are responsible for an error, and held the "extent to which the exclusionary rule is justified by these deterrence principles varies with the culpability of the law enforcement conduct." (Herring, supra, 555 U.S. at p. 143.) "To trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningfully deter it, and sufficiently culpable that such deterrence is worth the price paid by the justice system. As laid out in our cases, the exclusionary rule serves to deter deliberate, reckless, or grossly negligent conduct, or in some circumstances recurring or systemic negligence." (Id. at p. 144.) However, "when police mistakes are the result of negligence . . . rather than systemic error or reckless disregard of constitutional requirements, any marginal deterrence does not 'pay its way.' . In such a case, the criminal should not 'go free because the constable has blundered.'" (Id. at pp. 147-148.) The Court considered whether exclusion of seized evidence was warranted if an officer reasonably believed there was an outstanding arrest warrant, but that belief turned out to be wrong because of a negligent bookkeeping error by another police employee. Herring, 555 U.S. at , 172. The Court ultimately concluded that exclusion of the evidence was not required even though a fourth-amendment violation occurred. Herring, 555 U.S. at, 172. The Court held that where an officer reasonably but mistakenly believed there was an outstanding arrest warrant based on a negligent bookkeeping error by another police employee, suppression of contraband found during a search incident to the arrest was not required, despite the Fourth Amendment violation. (Id. at p. 698.) The Court observed that "our cases establish that such suppression is not an automatic consequence of a Fourth Amendment violation. Instead, the question turns on the culpability of the police and the potential of exclusion to deter wrongful police conduct." (Ibid.) The Court held that "the error was the result of isolated negligence attenuated from the arrest . . . and that in these circumstances the jury should not be barred from considering all the evidence." (Ibid.)