State of Tennessee v. Angela Faye Daniel

Summary

The Tennessee Supreme Court considered whether evidence from a blood draw conducted under a search warrant must be suppressed because the arresting officer failed to leave the defendant a copy of the warrant. The court held that a good-faith exception to Tennessee Rule of Criminal Procedure 41 applied because the officer’s omission was inadvertent and caused no prejudice. The court reversed the Court of Criminal Appeals and remanded the case for further proceedings.

Holdings

1. A narrow good-faith exception applies to Rule 41's exclusionary rule when the technical noncompliance results from a simple, isolated oversight or inadvertence, is not deliberate, reckless, grossly negligent, or part of multiple careless errors, and causes no prejudice to the defendant.
2. After a defendant demonstrates technical noncompliance with Rule 41 or a related statute, the State bears the burden of proving by a preponderance of the evidence that the noncompliance resulted from a good-faith error and caused no prejudice. If the State proves both, the trial court may determine in its discretion whether the violation was sufficiently inadvertent and inconsequential to qualify for the exception.
3. The officer's failure to provide Daniel with a copy of the search warrant did not require suppression because it was a good-faith, inadvertent technical violation that caused no prejudice under the specific facts of the case.
4. The Exclusionary Rule Reform Act was unavailable to save the evidence because the Tennessee Supreme Court had held the Act unconstitutional under the Tennessee Constitution's Separation of Powers Clause.

Questions Presented

1. Whether the failure to leave a copy of a search warrant with the person searched requires suppression under Tennessee Rule of Criminal Procedure 41(g)(6).
2. Whether a judicially created good-faith exception applies to Rule 41's exclusionary rule when the officer's failure to provide the warrant was an inadvertent technical violation that caused no prejudice.
3. Whether the Exclusionary Rule Reform Act, Tennessee Code Annotated section 40-6-108, exempted the evidence from suppression.

Disposition

reversed_and_remanded