The Tennessee Supreme Court has recognized a good-faith exception to the exclusionary rule, which means that evidence obtained in violation of a suspect’s constitutional right to be free from unreasonable searches and seizures need not be excluded from a criminal trial if the law enforcement officers’ actions rely in good faith on binding appellate precedent that is subsequently overruled.
The case arose from an October 29, 2011 single-vehicle accident in Knox County. The defendant, Corrin Reynolds, was allegedly driving the vehicle at the time of the accident. Two passengers died in the crash, and Reynolds and another passenger sustained injuries and were taken to UT Medical Center for treatment. Law enforcement officers investigating the crash obtained a sample of Reynolds’s blood without a warrant, believing that a warrant was not necessary because Reynolds had consented to the blood draw and because the accident involved fatalities.
Six months later, Reynolds was charged with two counts of vehicular homicide, one count of vehicular assault, one count of reckless endangerment, and four counts of driving under the influence of an intoxicant.
Before her trial, Reynolds asked the trial court to exclude any evidence obtained from her blood, claiming the officer had violated her state and federal constitutional right to be free from unreasonable searches and seizures when he obtained her blood without a warrant. Reynolds also argued that, because of the trauma of the accident, the medications she received, and her hearing impairment, she had been incapable of consenting to the blood draw. The trial court agreed, finding that Reynolds’s blood had been obtained without her consent and in violation of her constitutional rights, and granted her request to exclude the evidence from trial.
The State sought and received permission to appeal the trial court’s ruling, and the Court of Criminal Appeals reversed. Although the intermediate appellate court agreed that Reynolds had not actually consented to the blood draw, it held, based on a law passed by the Tennessee legislature, that Reynolds had impliedly consented to the warrantless blood draw when she drove a vehicle on Tennessee roadways.
As a result, the intermediate appellate court concluded that Reynolds’s constitutional rights had not been violated and evidence from her blood should not be excluded from trial. Recognizing that Reynolds could seek review of its decision in the Supreme Court, the Court of Criminal Appeals alternatively opined that, even if Reynolds’s constitutional rights were violated, the Tennessee Supreme Court should adopt and apply the good-faith exception to the exclusionary rule, which had already been adopted by the United States Supreme Court. Were the good-faith exception adopted and applied, the intermediate appellate court explained that evidence obtained from Reynolds’s blood need not be suppressed because her blood had been obtained in good-faith reliance on the implied consent law and a decision of the United States Supreme Court indicating that warrants were not required to obtain blood from DUI suspects.
The Tennessee Supreme Court granted Reynolds’s permission to appeal and asked the parties to address whether it should adopt a good-faith exception. In a 4-to-1 decision released today, the Supreme Court adopted a narrow good-faith exception to the exclusionary rule, which applies to prevent exclusion of evidence obtained in violation of a suspect’s constitutional rights only when the law enforcement officers act “in objectively reasonable good-faith reliance on ‘binding appellate precedent’ that ‘specifically authorizes a particular police practice’” and which is later overruled.
The Supreme Court held that evidence derived from Reynolds’s blood need not be suppressed because, when the officer obtained her blood without a warrant, a United States Supreme Court decision had been interpreted by Tennessee courts as authorizing the police to obtain blood without a warrant from DUI suspects. This binding appellate precedent was overruled after the officer obtained Reynolds’s blood. Accordingly, the Supreme Court concluded that the good-faith exception applied and remanded this case for further proceedings, including Reynolds’s trial.
Justice Sharon G. Lee dissented and described the Court’s decision to adopt the good-faith exception to the exclusionary rule for a constitutional violation as “ill-conceived.” In her view, the Court’s adoption of a good-faith exception to excuse a constitutional violation erodes citizens’ rights to be free from unreasonable searches and seizures as guaranteed by the United States and Tennessee Constitutions. Justice Lee expressed concern that this exception for a constitutional violation undermines judicial integrity by creating a grace period during which the police may violate constitutional requirements with impunity.
Justice Lee pointed to the disparate treatment given to a defendant in a United States Supreme Court case and a defendant in a case in Texas where the blood test results were not admitted into evidence and a good-faith exception was not applied. In Justice Lee’s view, the good-faith exception adopted by the Court was not applicable to Ms. Reynolds because the Tennessee Supreme Court had never ruled on the issue and statements in Tennessee appellate decisions indicating that warrants were not required to obtain blood samples from DUI suspects were not uniform and not “binding appellate precedent” for purposes of applying the good-faith exception.
Read the majority opinion in State of Tennessee v. Corrin Reynolds, authored by Justice Cornelia A. Clark, and Justice Lee’s dissenting opinion, go to the opinions section of TNCourts.gov.