State of Tennessee v. Kevin L. Lawrence

We granted permission to appeal in this case pursuant to Tennessee Rule of Appellate Procedure 11 to determine whether the trial court properly denied the defendant’s motion to suppress evidence obtained during the investigation of a shooting death. To resolve this issue, we must determine whether the investigators had probable cause to arrest the defendant and whether the delay in taking him before a magistrate for a judicial determination of probable cause should independently require the exclusion of the evidence obtained during the first few hours of his detention. Because we are of the opinion that the officers had probable cause to arrest the defendant, we conclude that the evidence recovered at the scene was not subject to suppression. As to the defendant’s claim of “unreasonable delay,” it is obvious that the defendant was not taken before a magistrate for a judicial determination of probable cause within a constitutionally reasonable time. However, the evidence the defendant sought to suppress was obtained during the first few hours of his arrest. Thus, these evidentiary items were not tainted by exploitation of the constitutional violation and are not, therefore, subject to suppression. Accordingly, we affirm the judgment of the Court of Criminal Appeals.