United States v. Leon, 468 U.S. 897; 104 S. Ct. 3405; 82 L. Ed. 2d 677 (1984)

United States v. Leon, 468 U.S. 897; 104 S. Ct. 3405; 82 L. Ed. 2d 677 (1984)

Facts—Police obtained a facially valid search warrant to conduct a search from which they gained evidence that resulted in an indictment for possessing and distributing cocaine. This evidence was suppressed in the U.S. District Court on the basis that the affidavit had been inadequate to sustain probable cause. The U.S. Ninth Circuit affirmed this judgment.

Question—Should the exclusionary rule apply where law enforcement officials obtained evidence in reasonable, good faith reliance on a search warrant?

Decision—No, there is a good faith exception to the exclusionary rule.

ReasonsJ. White (6–3). Although some decisions have implied that the exclusionary rule “is a necessary corollary of the Fourth Amendment,” this is not the case. As the Court stated in United States v. Calandra, 414 U.S. 338 (1974), the rule is “a judicially created remedy designed to safeguard Fourth Amendment rights generally through its deterrent effect, rather than a personal constitutional right of the party aggrieved.” The rule exacts “substantial social costs,” and has accordingly undergone some modifications, especially where its deterrent effect is attenuated. Deference to magistrates should not apply when officers knowingly provide false information, when the magistrate acts as a mere rubber stamp, or where an affidavit does not give a substantial basis for establishing probable cause. However, the exclusionary rule has particularly limited scope in regard to magistrates for three reasons. First, it “is designed to deter police misconduct rather than to punish the errors of judges.” Second, there is no evidence that judges have tried to subvert the Fourth Amendment. Third, there is no basis for believing that such exclusion would deter illegal conduct. In cases where officers are acting in good faith reliance on a search warrant, “the marginal or nonexistent benefits produced by suppressing evidence obtained . . . cannot justify the substantial costs of exclusion.”

J. Blackmun, concurring, indicated that any “empirical judgment about the effect of the exclusionary rule in a particular class of cases necessarily is a provisional one.”

J. Brennan, dissenting, viewed this as the last of a number of cases that erode the Fourth Amendment. He saw the purpose of the Fourth Amendment as being broader than that of mere deterrence. Members of the judiciary are as duty-bound by the provisions of the Fourth Amendment as are law enforcement officials. The judiciary is not in a position effectively to assess costs and benefits. This decision “will tend to put a premium on police ignorance of the law.”

J. Stevens, dissenting, believed this decision departed from settled precedents. The Fourth Amendment represents values higher than expediency.

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