United States v. Leon

468 U.S. 897 (1984), argued 17 Jan. 1984, decided 5 July 1984 by vote of 6 to 3; White for the Court, Blackmun concurring, Brennan, Marshall, and Stevens in dissent. In Leon, the Court heard arguments regarding whether it should create a broad exception to the Fourth Amendment's exclusionary rule for good‐faith police mistakes. The Court did create an exception to the rule that allows evidence seized in almost all searches conducted pursuant to unconstitutional warrants to be used without restriction in criminal prosecutions. Notwithstanding that it is frequently labeled as “the good‐faith exception,” however, the Leon exception is actually more limited in scope, and based on a different rationale, than the broad exception that had been proposed.

The idea for a good‐faith exception came from critics of the exclusionary rule, who asserted that many unconstitutional searches were made simply because the police made honest mistakes about confusing search rules. These critics also argued, applying the deterrence rationale for the exclusionary rule adopted in United States v. Calandra (1974), that suppressing evidence that was seized unconstitutionally because of honest police mistakes served no purpose because the police could not be deterred from future unconstitutional searches if they had acted by mistake. Thus, the critics proposed that unconstitutionally seized evidence should be admissible in criminal trials whenever the police had acted because of a good‐faith, albeit mistaken, belief that the search was constitutional.

Defenders of the exclusionary rule opposed the proposed exception on the ground that unconstitutionally seized evidence should be suppressed as a matter of principle to enforce Fourth Amendment rights and to protect the integrity of the courts. They also expressed doubt that honest mistakes are a frequent cause of illegal searches and argued that there is no reason to think that suppression of evidence would be less likely to deter future police misconduct just because the police had made a mistake. Defenders of the rule also questioned whether courts could reliably distinguish between mistaken and willful unconstitutional searches and, as a result, voiced concern that any good‐faith mistake exception would be so open‐ended in practice that it would effectively end enforcement of Fourth Amendment search standards.

Although Justice Byron White's majority opinion is clearly influenced by the proposal for a broad good‐faith exception, the Leon exception is more limited in both its scope and its rationale. With regard to its scope, the Leon exception is explicitly limited to searches for which the police have obtained a search warrant that is later ruled to be invalid. Most police searches are, however, conducted without search warrants. Thus, as a practical matter, it is doubtful that the Leon exception will affect evidence in many cases, especially because search warrants were rarely found to be invalid even prior to Leon.

With regard to Leon's rationale, White did not discuss police “good faith” generally but justified the exception on the narrow premise that the police should not be asked to second guess the validity of a judge's decision to issue a search warrant. He asserted that the exclusionary rule was only designed to reach police misconduct, not judicial errors; hence, he concluded that the rule should not apply to an invalid search warrant that is the fault of a judge rather than the police. Because of this narrow rationale, it is questionable whether Leon should be viewed as precedent for a broad good‐faith exception that would apply to unconstitutional warrantless searches. Nevertheless, Leon is a significant development because it is the first decision to find a Fourth Amendment violation but nevertheless allow unrestricted use of unconstitutionally seized evidence in criminal proceedings, including the prosecution's case‐in‐chief at trial. At least implicitly, Leon appears to embrace the proposition that there need not be any recourse or remedy available to victims of Fourth Amendment violations.

Justice William J. Brennan's dissent, joined by Justice Thurgood Marshall, rejected the entire approach of the majority opinion. It argued that suppression of unconstitutionally seized evidence is constitutionally required without regard to its deterrent effect. Hence, the reason the violation occurred should be legally irrelevant.

See also Exclusionary Rule; Fourth Amendment; Search Warrant Rules, Exceptions to.

— Thomas Y. Davies

• 468 U.S. 897 (1984)
• Vote: 6–3
• For the Court: White
• Concurring: Blackmun
• Dissenting: Brennan, Marshall, and Stevens

In 1981 the police in Burbank, California, received information about drug dealing by two residents of their city. So the police began to regularly watch the Burbank home of the two suspects, where they spotted an automobile owned by Alberto Leon, another suspected drug dealer.

The Burbank police obtained a search warrant from a local judge, searched the residence, and found illegal drugs belonging to Alberto Leon. This evidence led to Leon's arrest and conviction.

The Issue

Leon's lawyer argued that the search warrant used by the Burbank police was not valid because there was no “probable cause” for the police to request it or for the judge to issue it. As a result, the evidence against Leon gathered by the police should have been thrown out under the exclusionary rule established in Mapp v. Ohio (1961), according to which evidence obtained in violation of a person's constitutional rights cannot be used to prosecute the person. Should the evidence against Leon be excluded because it was obtained through procedures that violated the 4th Amendment guarantee to “the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures”? Or should the Supreme Court permit an exception to the exclusionary rule when the police make a “good faith” mistake in obtaining and using a search warrant?

Opinion of the Court

The Supreme Court acknowledged that the police used an invalid search warrant to obtain evidence against Leon. Nonetheless, the Court ruled against Leon and permitted a “good faith” exception to the exclusionary rule. The exclusionary rule is not a constitutional right, said Justice Byron White, but merely serves to limit oppressive police actions. However, when police act on “good faith” to obtain valid evidence of criminal behavior, the exclusionary rule does not apply to the case.

Dissent

Justice William Brennan, who had established the exclusionary rule in Mapp v. Ohio, opposed any “good faith” exception to this rule. He feared that this exception would lead to an increase in illegal police behavior in gathering evidence against people suspected of criminal behavior.

Significance

The Leon decision narrowed the exclusionary rule protections under the 4th Amendment of the Constitution. This outcome was hailed by many law enforcement officials, who often felt frustrated by judicial decisions that permitted a criminal to avoid conviction because of a technical error by the police. However, defenders of the exclusionary rule argued against any exceptions to it because of their strong commitment to 4th Amendment rights.

See also Exclusionary rule; Mapp v. Ohio; Searches and seizures

United States v. Leon
Supreme Court of the United States
Argued January 17, 1984 Decided July 5, 1984
Full case name: United States v. Leon et al. Citations: 468 U.S. 897 Prior history: Certiorari to the United States Court of Appeal for the Ninth Circuit. Subsequent history: 701 F.2d 187, reversed.
Holding
Established that evidence obtained in good faith by police relying upon a search warrant that subsequently is found to be deficient may be used in a criminal trial.
Court membership
Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Byron White, Thurgood Marshall, Harry Blackmun, Lewis Franklin Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor
Case opinions
Majority by: White Joined by: Burger, Blackmun, Powell, Rehnquist, O'Connor Concurrence by: Blackmun Dissent by: Brennan Joined by: Marshall Dissent by: Stevens
Laws applied
U.S. Const. amend. IV

United States v. Leon, 468 U.S. 897 (1984)^[1], was a search and seizure case in which the Supreme Court of the United States created the "good faith" exception to the exclusionary rule.

Background

In 1981, police in Burbank, California received a tip identifying Patsy Stewart and Armando Sanchez as drug dealers. Police began surveillance of their homes and followed leads based on the cars that frequented the residences. The police identified Ricardo Del Castillo and Alberto Leon as also being involved in the operation. Based on this surveillance and information from a second informant, a detective wrote an affidavit and a judge issued a search warrant.

Arguments

The exclusionary rule (which forbids evidence obtained through illegal search and seizure from admittance in criminal trial) is "neither intended nor able to 'cure the invasion of the defendant's rights which he has already suffered.'" He states that the Court has previously defined the limits of the exclusionary rule and that there is therefore good reason to do so in this case. The exclusionary rule was designed to deter unlawful police action, not punish the errors of magistrates. There is no evidence that judges and magistrates are inclined to ignore suspects' Fourth Amendment rights. White also states that there is no evidence that the exclusion of evidence will deter magistrates from issuing unsound warrants.

White clarifies that suppression of evidence should continue in cases where the magistrate was misled by information supplied in an affidavit in "bad faith". As long as the person writing the affidavit wrote it in good faith, the decision is that of the magistrate and the exclusionary rule serves no useful function. The officers enforcing the warrant must be able to rely on the decision of the magistrate.

External links

• ^ 468 U.S. 897 (Text of the opinion from Findlaw.com)
• OYEZ Case Review

Bibliography

• Hemmens C, Worrall JL, Thompson A. Criminal Justice Case Briefs: Significant Cases in Criminal Procedure. Los Angeles: Roxbury Publishing, 2004. ISBN 1-931719-23-3

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