Summary
In Herring v. United States, 555 U.S. 135 (2009), the Supreme Court held that evidence found after an arrest based on an outdated warrant record did not have to be suppressed. The exclusionary rule turns on whether suppression would deter sufficiently culpable police conduct, not on every negligent recordkeeping mistake.
Legal Issue
Does the Fourth Amendment exclusionary rule require suppression of evidence found during an arrest based on an erroneous police database entry showing an active warrant?
Holding
No. The Supreme Court held that exclusion applies only when police misconduct is sufficiently deliberate, reckless, grossly negligent, or systemic enough that suppression meaningfully deters it. Isolated negligence from a recordkeeping error did not justify excluding the evidence.
Rule of Law
A bad warrant record can violate the Fourth Amendment, but evidence will not automatically be thrown out. Courts ask whether suppression would realistically deter serious or recurring police misconduct.
Court Reasoning
Not yet summarized.
Impact for Officers
The case remains important in warrant-database, records-management, and good-faith exception disputes, especially where courts must distinguish isolated negligent errors from systemic failures.
What Officers Can Do
Not yet summarized.
What Officers Should Avoid
Not yet summarized.
Common Misunderstanding
Not yet summarized.