IN: AL warrant in NCIC justified arrest, and PC for warrant was irrelevant to the basis for the search incident

Arrest in Indiana on a NCIC Alabama warrant that led to finding a gun was sufficient to prosecute in Indiana. There was no reason to go behind the probable cause finding in Alabama because the sole issue in Indiana is possession of the gun. Shotts v. State, 925 N.E.2d 719 (Ind. 2010):

At the outset, it is important to bear in mind what the issue in this case is and what it is not. We are addressing whether we are to suppress the evidence of Shotts’s possession of a weapon in this Indiana prosecution charging violation of Indiana’s gun laws. We are not addressing whether this evidence may be admitted in any prosecution in Alabama for the charges that gave rise to the Alabama warrant. The first issue, therefore, is whether only the reasonableness of the Indiana officers’ conduct is required for a valid arrest, or is the Alabama probable cause determination also subject to challenge. It is well settled that in extradition proceedings the receiving state is not to review the probable cause determination of the demanding state. See, e.g., Bailey v. Cox, 260 Ind. 448, 452, 296 N.E.2d 422, 425 (1973) (discussing the Uniform Criminal Extradition Act, currently codified at I.C. § 35-33-10-3, and concluding that any challenge to the arrest warrant must be resolved in the demanding state). We find little direct authority addressing whether the same reasoning applies to evaluation of an arrest in a receiving state–in this case Indiana–based on a warrant issued by another state–in this case Alabama. For the reasons explained below, we conclude that it does.

Even if the Alabama warrant was defective, suppression of the discovered gun in the Indiana proceeding “is not an automatic consequence.” Herring, 129 S. Ct. at 698. Suppression of evidence under controlling Fourth Amendment precedent “turns on the culpability of the police and the potential of exclusion to deter wrongful police conduct.” Id. Specifically, invalidity of a warrant does not necessarily require exclusion of evidence seized under its authority. Id. at 701. Even if a warrant is invalid for lack of probable cause, “the exclusionary rule does not apply if the police acted ‘in objectively reasonable reliance’ on the subsequently invalidated search warrant.” Id. (quoting United States v. Leon, 468 U.S. 897, 922 (1984)). “[E]vidence should be suppressed ‘only if it can be said that the law enforcement officer had knowledge, or may properly be charged with knowledge, that the search was unconstitutional under the Fourth Amendment.'” Illinois v. Krull, 480 U.S. 340, 348-349 (quoting United States v. Peltier, 422 U.S. 531, 542 (1975)). Put differently, the high cost associated with suppression is appropriate only where police acts are “sufficiently culpable” and suppression can “meaningfully deter” those acts. Herring, 129 S. Ct. at 702. The “good-faith inquiry is confined to the objectively ascertainable question whether a reasonably well trained officer would have known that the search was illegal” in light of “all of the circumstances.” Leon, 468 U.S. at 922 & n.23.

The trial court found that the Indiana officers acted in good-faith reliance on a warrant they reasonably presumed to be valid. This finding is fully supported in the record and disposes of Shotts’s claim under the Fourth Amendment.