The following excerpt is from Vasquez v. Maloney, 990 F.3d 232 (2nd Cir. 2021):
The Officers suggest that our decision in United States v. Santa , 180 F.3d 20 (2d Cir. 1999), supports their claim to qualified immunity. But that precedent only highlights where their argument falters. In Santa , officers arrested the defendant based on an erroneous police computer record indicating that he was wanted on an outstanding warrant. Id. at 24. The warrant had in fact been vacated, but due to a clerical error by court employees, it was never removed from the police database. Id. at 2223. Before arresting the defendant, the officers had requested a "wanted person check" from the dispatcher to determine whether there was an outstanding warrant. Id . at 24. The dispatcher checked the police database and separately confirmed with the originating department, which faxed a copy of the warrant to the requesting department, and radioed the information back to the officersall based on incorrect information resulting from the clerical error. Id . Because the officers reliance on the erroneous computer record was objectively reasonable and the error was attributable to court employees rather than improper police practices, we declined to suppress evidence found on the defendant's person pursuant to the exclusionary rule. Id . at 30.
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