Washington v. Betancourth

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This case required the Washington Supreme Court to consider the "independent source doctrine," a recognized exception to the exclusionary rule under article I, section 7 of the Washington State Constitution. The superior court admitted into evidence Ray Betancourth's cell phone records, which were initially obtained under a jurisdictionally invalid district court warrant. In 2012, Betancourth assembled a group of friends to look for Terrance Frank, whom Betancourth suspected of breaking his car windows a few days earlier. Betancourth drove the group around in his pickup truck until they located Frank walking down the sidewalk with two other men, Jordan Lemus and Jose Rodriguez. Betancourth's group exited the truck and chased after Frank, Lemus, and Rodriguez. Betancourth turned back after realizing he had left his truck running, while his friends chased Lemus and Rodriguez into an alley. Betancourth's friend, Marco Cardenas, pulled out a pistol and fired twice, killing Rodriguez. Almost a year after Betancourth's arrest, a superior court judge ruled in a separate case that RCW 10.96.060 authorized only superior courts to issue warrants for the records of out-of-state companies. Based on this ruling, police obtained a new warrant for Betancourth’s Verizon phone records. Though a valid superior court warrant was subsequently issued, police did not physically return and reseize the evidence. In upholding admission of the cell phone records, the Court of Appeals fashioned what it deemed an "invalidity correction corollary" to the independent source doctrine Betancourth argued this corollary improperly interjected reasonableness or good faith considerations that were incompatible with Washington constitutional privacy rights. The Supreme Court affirmed the Court of Appeals: “[w]hile we do not embrace the notion of an ‘invalidity correction corollary,’ we agree with the lower courts that the exclusionary rule does not apply in this case. We hold that Betancourth's cell phone records were admissible under our existing independent source doctrine.” View "Washington v. Betancourth" on Justia Law