Davis v. United States

131 S.Ct. 2419 (2011)

Facts

Officers conducted a routine traffic stop that eventually resulted in the arrests of driver Stella Owens (for driving while intoxicated) and passenger, D, (for giving a false name to police). The police handcuffed both Owens and D, and they placed the arrestees in the back of separate patrol cars. The police then searched the passenger compartment of Owens's vehicle and found a revolver inside D's jacket pocket. D motioned to suppress the revolver. D acknowledged that the officers' search fully complied with “existing Eleventh Circuit precedent.” D was convicted, and while D's appeal was pending, this Court decided Gant. The Eleventh Circuit applied Gant's new rule and held that the vehicle search incident to D's arrest “violated [his] Fourth Amendment rights.” As for whether this constitutional violation warranted suppression, the Eleventh Circuit viewed that as a separate issue that turned on “the potential of exclusion to deter wrongful police conduct.” The court concluded that “penalizing the [arresting] officer” for following binding appellate precedent would do nothing to “deter . . . Fourth Amendment violations. D appealed.