Christopher L. Carpenter v. State of Florida

Summary

The Florida Supreme Court reviews whether the good-faith exception to the Fourth Amendment exclusionary rule applies to a warrantless search of a cell phone conducted in reliance on an earlier Florida district court decision. The court holds that the exception does not apply because the precedent was nonfinal and under active review, and it quashes the First District Court of Appeal's decision. The court also disapproves the Second District's reasoning in Willis to the extent it conflicts with the opinion.

Holdings

1. The Davis good-faith exception does not apply when officers rely on a nonfinal, pipeline decision concerning an unsettled and rapidly developing Fourth Amendment issue while that decision is under active review by the Florida Supreme Court.
2. The evidence obtained from the warrantless search of Carpenter's cell phone is subject to the exclusionary rule because the officers' reliance on Smallwood I was not objectively reasonable under Davis.
3. Willis reached the correct result, but its reasoning is disapproved to the extent it conflicts with Carpenter.

Questions Presented

1. Whether the Davis v. United States good-faith exception to the exclusionary rule applies when officers conduct a warrantless cell-phone search in reliance on a nonfinal Florida district-court decision that is under active review by the Florida Supreme Court and concerns a rapidly developing area of Fourth Amendment law.
2. Whether evidence obtained from Carpenter's cell phone was subject to suppression under the Fourth Amendment.

Disposition

quashed