KY: Click on wrong name on LPN reader screen same as erroneous warrant; exclusionary rule not applied because of mere negligence

An officer on patrol was running LPNs to see what he’d find. On defendant’s vehicle, a list a names came up, and the officer accidentally clicked on the wrong name resulting in defendant’s stop for an outstanding warrant that didn’t exist. Under Herring, the exclusionary rule wouldn’t be applied. “Assuming the stop to be improper, the trial court’s analysis of the facts through the lens of Herring is appropriate. Schneble’s errant click on the similar name of the wrong person does not reflect recurring or systemic negligence, wantonness, recklessness, or gross negligence. It is not the type of police misconduct the exclusionary rule is designed to deter.” Bowen v. Commonwealth, 2016 Ky. App. LEXIS 163 (Sept. 16, 2016).