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Name: People v. Hamilton
Case #: A097329
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 10/21/2002
Subsequent History: none
Summary

Appellant’s vehicle was stopped because a computerized DMV report showed it had an expired registration. A search turned up cocaine and a firearm. The DMV report turned out to be inaccurate. The trial court denied appellant’s suppression motion, holding that the good faith exception to the exclusionary rule applied. Here, the appellate court affirmed the denial of the suppression motion. Even though the Supreme Court in People v. Willis (2002) 28 Cal. 4th 22 held that the good faith exception did not apply where police relied on erroneous information from parole authorities, that case can be distinguished from this one. The purpose of the exclusionary rule is to deter misconduct by law enforcement officials, and a DMV clerk is not a law enforcement official. A good faith exception to the exclusionary rule may apply when a DMV clerk creates an erroneous data base entry subsequently relied on by a police officer who reasonably relies on its accuracy.