Utah v. Strieff

Salt Lake City police officer Douglas Fackrell received an anonymous tip that drug activity was taking place at a residence. Fackrell observed many people visit the home for a few minutes and leave. Fackrell saw Edward Strieff (defendant) exit the home. Although Fackrell had not seen Strieff enter, Fackrell was suspicious that drug activity was occurring and approached Strieff. Fackrell asked Strieff what he was doing there and demanded his identification. Fackrell relayed Strieff’s identity to a police dispatcher who reported that Strieff had an outstanding arrest warrant. Fackrell placed Strieff under arrest and conducted a search incident to the arrest. Strieff had a baggie of methamphetamine in his possession. Strieff was charged with unlawful drug possession. Strieff argued that the drugs should be suppressed because Fackrell lacked reasonable suspicion for a seach and had conducted an unlawful investigatory stop. The state conceded that the stop was unlawful. However, the state argued that the evidence was admissible because the warrant separated the unlawful stop from the discovery of the drugs. The trial court admitted the evidence, and Strieff pled guilty, reserving the right to appeal the evidentiary issue. The Utah Court of Appeals affirmed. The Utah Supreme Court reversed, finding the evidence should have been suppressed. The United States Supreme Court granted certiorari.