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Introduction to Suppression Law

Suppression law involves the legal principles and procedures used to exclude certain evidence from being presented in court. This typically occurs when evidence is obtained in violation of a defendant’s constitutional rights. Suppression law is fundamental in protecting individuals’ Fourth Amendment rights against unreasonable searches and seizures.

What is a Motion to Suppress?

A motion to suppress is a legal request made by a defendant, asking the court to exclude specific evidence from trial. The goal is to ensure that evidence obtained unlawfully, without probable cause, or through coercion, does not prejudice the defendant’s right to a fair trial.

Key Points of Suppression Law

1. Fourth Amendment Rights: The Fourth Amendment protects individuals against unreasonable searches and seizures. Evidence obtained without a valid warrant or probable cause is generally inadmissible in court.

2. Probable Cause: Law enforcement must have probable cause to believe that a crime has been committed and that the person or place to be searched is connected to the crime.

3. Exclusionary Rule: This rule prevents illegally obtained evidence from being used in court. It acts as a deterrent against unlawful searches and seizures.

4. Good Faith Exception: If law enforcement officers acted in good faith, believing their conduct was lawful, the evidence may still be admissible even if the search warrant is later found to be invalid.

Example Case: State of Indiana v. John Doe

In the case of State of Indiana v. John Doe, Doe filed a motion to suppress evidence obtained through a warrantless search of his cell site location information (CSLI) and phone activity. Doe argued that the search violated his Fourth Amendment rights, as the officers lacked probable cause.

Case Details

• Incident Date: May 5, 2024
• Detective: Douglas Cook of the Hancock County Sheriff’s Department
• Warrant Application: The warrant application included information about a burglary that occurred on May 5, 2024, at 4:12 am. The victims could not identify the suspects, who were wearing black hoodies.

Argument in Support of Defendant’s Motion to Suppress Evidence

1. Lack of Probable Cause: The defense argued that the warrant affidavit failed to establish a fair probability that Doe committed the burglary. The affidavit did not link Doe to the crime scene or the elements of the burglary. Probable cause requires concrete facts connecting the individual to the alleged crime, which were absent in this case.

2. No Conclusive Statements: The affidavit did not include any conclusive statements that Doe knew about the property or the victims. Additionally, there was no indication that Doe was aware of the burglary on May 5. The lack of connection between Doe and the crime scene undermined the validity of the warrant.

3. No Criminal History: Doe had no prior criminal history, which further weakened the argument for probable cause. The defense pointed out that mere presence near the crime scene days before the incident does not constitute probable cause for a search.

4. Failure to Describe Suspicious Behavior: The police did not provide an explanation of why Doe’s voluntary explanation on May 2 was considered suspicious. Doe was resting in a field near the crime scene, but this alone did not link him to the burglary.

5. Insufficient Connection: The affidavit relied on Doe’s vehicle being seen near the area on various dates, but this did not establish a connection to the crime. The defense emphasized that proximity to the crime scene is not enough to justify a search without additional evidence linking the individual to the offense.

6. Good Faith Exception: The defense argued that the good faith exception did not apply, as a reasonable officer would not rely on an affidavit that failed to connect the defendant to the crime. The affidavit’s deficiencies indicated that the search was based on a hunch rather than concrete evidence.

Importance of Suppression Law

Suppression law is crucial in safeguarding individuals’ constitutional rights and ensuring that law enforcement operates within legal boundaries. By upholding the principles of suppression law, the justice system can prevent abuses of power and maintain the integrity of the legal process.

Full Text of Brief

MEMORANDUM IN SUPPORT OF DEFENDANT’S

            Doe respectfully submits this Memorandum in Support of Defendant’s Motion to Suppress Evidence. The State circumvented the Fourth Amendment of the Constitution of the United States during an investigation into Doe for burglary. Officers lacked probable cause, yet they secured both Doe’s CSLI and Doe’s communication activity from his cell service provider. This information connected Doe phone to the precise scene of a home invasion, as well as to other phones located at the scene. For the reasons outlined in the next paragraph and then developed in the Argument Section below, Doe requests that this Court suppress the resulting evidence. 

An objectively-reasonable and trained officer would have known that searching Doe’s CSLI and other phone activity was illegal. Probable cause only exists when police can link facts to the elements of a crime. Here, police could neither place Doe at the scene nor point to a crime he had committed anywhere — let alone to a crime that occurred three days later at a separate location. Indiana citizens do not forfeit their Fourth Amendment rights merely because they step off of public property while located about .25 miles away from a future crime. Because the warrant was based on a hunch, a trained officer would have known that he or she needed to investigate further.