SUPREME COURT OF THE UNITED STATES
OCTOBER TERM, 1994
certiorari to the supreme court of arizona
No. 93-1660. Argued December 7, 1994—Decided March 1, 1995
Respondent was arrested by Phoenix police during a routine traffic stop when a patrol car's computer indicated that there was an outstanding misdemeanor warrant for his arrest. A subsequent search of his car revealed a bag of marijuana, and he was charged with possession. Respondent moved to suppress the marijuana as the fruit of an unlawful arrest, since the misdemeanor warrant had been quashed before his arrest. The trial court granted the motion, but the Court of Appeals reversed on the ground that the exclusionary rule's purpose would not be served by excluding evidence obtained because of an error by employees not directly associated with the arresting officers or their police department. In reversing, the Arizona Supreme Court rejected the distinction between clerical errors committed by law enforcement personnel and similar mistakes by court employees and predicted that the exclusionary rule's application would serve to improve the efficiency of criminal justice system recordkeepers.
Held: 1. This Court has jurisdiction to review the State Supreme Court's decision. Under Michigan v. Long, 463 U. S. 1032, when a state-court decision fairly appears to rest primarily on federal law, or to be interwoven with federal law, and when the adequacy and independence of any possible state-law ground is not clear from the opinion's face, this Court will accept as the most reasonable explanation that the state court decided the case the way it did because it believed that federal law required it to do so. This standard for determining whether a
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