Summary
The Washington Supreme Court held that the warrant-based search of Adams’s vehicle violated the Fourth Amendment and article I, section 7 of the Washington Constitution because Adams was not within reaching distance of the passenger compartment and the search was not justified by officer-safety concerns or the need to preserve evidence. Applying Arizona v. Gant, State v. Patton, and State v. Afana, the court rejected the State’s proposed good-faith exception to the exclusionary rule and reversed Adams’s conviction.
Topics
Practice areas
Questions Presented
- Whether the warrantless search of Adams's vehicle was a valid search incident to arrest under the Fourth Amendment and article I, section 7 of the Washington Constitution.
- Whether Washington should recognize a good-faith exception to the exclusionary rule when officers relied on pre-Arizona v. Gant case law.
Holdings
- The search of Adams's vehicle was unlawful because Adams was not within reaching distance of the passenger compartment when the search occurred, and there was no officer-safety concern or need to secure evidence of the offense of arrest that justified the search.
- Washington does not recognize a good-faith exception under article I, section 7 of the Washington Constitution for officers who relied on pre-Gant case law in conducting the unlawful vehicle search.
Key quotations
“We reverse because Adams was not within reaching distance of the passenger compartment of the vehicle at the time of the search and the search was not triggered by officer safety concerns or the need to secure evidence of the crime for which he was arrested.” (¶1)
“Because the State concedes that Gant applies to the search in this case, and because we have declined to recognize a “good faith” exception based on pre-Gant case law in Afana, we reverse the conviction in this case.” (¶10)
Factual background
A deputy observed Coryell Adams in a parked car and learned that he had an outstanding warrant for driving with a revoked license. After Adams drove away and stopped in a nearby parking lot, he exited the vehicle, moved several steps away, and was arrested after another deputy arrived. Once Adams was secured in a patrol car, the deputy searched his vehicle and found cocaine in a bag in the center console.
Procedural history
Adams was charged with possession of cocaine after officers searched his vehicle following his arrest on an outstanding warrant. The trial court denied his suppression motion, relying on the recent-occupant rationale in Thornton v. United States. The Court of Appeals affirmed. After the United States Supreme Court decided Arizona v. Gant, the State conceded that Gant applied but argued for a good-faith exception to the exclusionary rule. The Washington Supreme Court rejected that argument and reversed.