Frimmel was the owner of several restaurants in Arizona, which were the targets of raids by the Maricopa County Sheriff's Office (MCSO) that were conducted in violation of the Fourth Amendment. MCSO then shared information with ICE, who began an investigation into Frimmel's employment of immigrants who did not have employment authorization. Frimmel moved to suppress the documents obtained by ICE before the Office of the Chief Administrative Hearing Officer (OCAHO), but his request was denied. The Arizona state court, in the meantime, suppressed the evidence obtained by the MCSO in the state criminal proceedings brought against Frimmel, finding multiple defects in the warrant used to conduct the search.
The Court determined that the MCSO's conduct was an egregious violation of the Fourth Amendment. Moreover, the Court found that ICE's evidence was fruit of the illegal search by MCSO, and that there was not sufficient attenuation between ICE obtaining the evidence and the illegal search. Finally, the Court determined that MSCO had immigration enforcement in mind when it conducted its unlawful raids, and thus, application of the exclusionary rule would have proper deterrent effect. As such, the Court reversed the administrative law judge's determination that the evidence obtained by ICE should not be suppressed in the OCAHO proceeding.
The full text of Frimmel v. United States can be found here: