State v. Strieff, 2015 UT 2 (Jan. 16, 2015) 

The Utah Supreme Court analyzed the applicability of the “attenuation doctrine” exception to the exclusionary rule in this case where the police’s unlawful detention of the defendant led to the discovery of an arrest warrant and was followed by a search incident to arrest. The court noted the lack of controlling authority from the United States Supreme Court, analyzed how other lower courts have handled the issue, and ultimately adopted its own new approach limiting application of the attenuation doctrine to factual scenarios involving intervening acts of a defendant’s free will, such as a confession or consent to a search. Applying this new standard, the court found that the attenuation doctrine was not implicated and therefore reversed the court of appeals’ decision upholding the district court’s denial of the defendant’s motion to suppress.