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relying on the record. produces such errors.

Here, the officers relied on their computer records In sum, there is nothing in the record that would
that listed Walker’s warrants. They did not have the show that Foster’s and Polk’s reliance on the
complaints underlying the warrants or other computer records was not objectively reasonable.
information that might have revealed possible The district court did not err in applying the good
invalidity. Like the Evans officer, Foster and Polk faith exception, and the officers were justified in
were only aware that warrants existed their reliance on the traffic warrants as a basis for
in Walker’s name. Indeed, Walker’s counsel stated arrest.
in his argument at the suppression hearing and in
his brief on appeal that even if the City of Houston Having determined that Walker’s traffic stop and
might be aware that the warrants are deficient, the arrest were both justified, we consider whether
police officers themselves are not. Without there was any impropriety in the discovery of the
“deliberate, reckless, or grossly negligent” conduct firearm and cell phone during the traffic stop.
on the part of the police, excluding evidence has Walker argues that even if his arrest were based on
little, if any, deterrent value and is therefore probable cause and his traffic stop justified, the
unjustified. evidence discovered should be excluded because
Walker’s statements to the officers informing them
Walker argues that even if the police officers did of the gun’s location were made before Miranda
not engage in deliberate or negligent conduct to warnings were given. Miranda requires an officer
invalidate the warrant, the good faith exception to advise suspects of various rights before
should not apply based on the reason for the errors. proceeding with custodial interrogation. A
Specifically, he alleges the City of Houston has custodial interrogation occurs when “a reasonable
adopted an unconstitutional policy that allows fill- person in the position of the suspect would
in-the-blank form complaints devoid of probable understand the situation to constitute a restraint on
cause to serve as the basis for arrest warrants. He freedom of movement to the degree that the law
contends the City of Houston issued tens of associates with formal arrest.”
thousands of deficient warrants just in 2020. The
Supreme Court has left the door open for such We set aside the issue of whether Walker was in
arguments, he claims, by concluding that when custody when he answered questions and instead
“police have been shown to be reckless in focus on whether it was inevitable that the officers
maintaining a warrant system, or to have knowingly would have discovered the firearm and cell phone.
made false entries to lay the groundwork for future The inevitable discovery doctrine is a limit on the
false arrests, exclusion would certainly be Fourth Amendment’s exclusionary rule.
justified.” The Court acknowledged that if It provides that “otherwise suppressible evidence
“systemic errors were demonstrated, it might be [will be admitted] if that evidence would
reckless for officers to rely on an unreliable warrant inevitably have been discovered by lawful means.”
system.” The Court found no evidence in Herring It applies if “the Government demonstrates by a
of such systemic errors. preponderance of the evidence that (1) there is a
reasonable probability that the contested evidence
Walker argues that part of the egregiousness of the would have been discovered by lawful means in
City of Houston’s allegedly unconstitutional system the absence of police misconduct and (2) that the
is that the City is “keeping police officers in the Government was actively pursuing a substantial
dark about the invalidity of the Houston municipal alternate line of investigation at the time of the
court warrants.” A warrant system that produces constitutional violation.”
routine or widespread errors raises serious
constitutional questions. Here, there is no Here, the officers were required to conduct an
evidence in the record that the City of Houston’s inventory search of Walker’s vehicle once he was
warrant system regularly, i.e., systemically, arrested. As we indicated above, the arrest was
valid. Once the vehicle was properly seized, an

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