''United States v. Leon'', 468 U.S. 897 (1984), was a
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case in which the Court established the "
good faith" exception to the
Fourth Amendment exclusionary rule
In the United States, the exclusionary rule is a legal rule, based on constitutional law, that prevents evidence collected or analyzed in violation of the defendant's constitutional rights from being used in a court of law. This may be consider ...
.
[.]
Background
In August 1981, police in
Burbank, California
Burbank is a city in the southeastern end of the San Fernando Valley in Los Angeles County, California, United States. Located northwest of downtown Los Angeles, Burbank has a population of 107,337. The city was named after David Burbank, w ...
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
Surveillance is the monitoring of behavior, many activities, or information for the purpose of information gathering, influencing, managing or directing. This can include observation from a distance by means of electronic equipment, such as c ...
and information from a second informant, a detective wrote an
affidavit
An ( ; Medieval Latin for "he has declared under oath") is a written statement voluntarily made by an ''affiant'' or '' deponent'' under an oath or affirmation which is administered by a person who is authorized to do so by law. Such a statemen ...
and a
judge
A judge is a person who presides over court proceedings, either alone or as a part of a panel of judges. A judge hears all the witnesses and any other evidence presented by the barristers or solicitors of the case, assesses the credibility an ...
issued a search warrant. The police conducted the search, but the search warrant was later found to be invalid because the police lacked the probable cause for a warrant to be issued in the first place. The evidence obtained in the search was upheld anyway, because the police performed the search in reliance on the warrant, meaning they acted in good faith. This became known as the good faith exception to the exclusionary rule.
Decision
Majority
The Supreme Court announced its decision on July 5, 1984, with Justice
Byron White
Byron "Whizzer" Raymond White (June 8, 1917 April 15, 2002) was an American professional football player and jurist who served as an associate justice of the U.S. Supreme Court from 1962 until his retirement in 1993.
Born and raised in Colo ...
filing for the 6–3 majority in favor of the United States, with Justice
Harry Blackmun
Harry Andrew Blackmun (November 12, 1908 – March 4, 1999) was an American lawyer and jurist who served as an Associate Justice of the Supreme Court of the United States from 1970 to 1994. Appointed by Republican President Richard Nixon, Blac ...
writing a concurring opinion.
First, the exclusionary rule is designed to deter police misconduct rather than to punish magistrates and judges for their errors. Only when a warrant is grounded upon an affidavit knowingly or recklessly false has the Court suppressed the evidence obtained as a result. Second, there exists no evidence that judges and magistrates are inclined to ignore the Fourth Amendment of the Constitution and that their actions would require the ultimate sanction of exclusion. Third, there is no evidence that suppression of evidence obtained under a search warrant will have any deterrent effect upon judges and magistrates. Judges and magistrates are not adjuncts to law enforcement officials and as such are neutral and have no stake in the outcome of criminal prosecutions.
The suppression of evidence obtained pursuant to a search warrant should be ordered only on a case-by-case basis and only in those instances where exclusion would promote the purposes of the exclusionary rule. An officer acting in good faith and within the scope of a search warrant should not be subjected to Fourth Amendment constitutional violations. It is the magistrate’s or judge’s responsibility to ascertain whether the warrant is supported by sufficient information to support probable cause. However, the officer’s reliance must be objectively reasonable. Suppression remains an appropriate remedy where the magistrate was misled by information in an affidavit that the affiant knew was false or would have known was false except for his reckless disregard for the truth.
In his concurrence, Justice Blackmun wrote, "If it should emerge from experience that, contrary to our expectations, the good faith exception to the exclusionary rule results in a material change in police compliance with the Fourth Amendment of the Constitution, we shall have to reconsider what we have undertaken here."
Dissent
Justice
William Brennan filed a dissenting opinion, joined by Justice
Thurgood Marshall
Thurgood Marshall (July 2, 1908 – January 24, 1993) was an American civil rights lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1967 until 1991. He was the Supreme Court's first African-A ...
, arguing that the Fourth Amendment of the Constitution must be read to condemn not only the initial unconstitutional invasion of privacy, but also the subsequent use of any illegally obtained evidence. The exclusionary rule was part and parcel of the Fourth Amendment’s limitation upon governmental encroachment of individual privacy. The Court’s only support for its decision is that even though the costs of exclusion are not very substantial, the potential deterrent effect in these circumstances is so marginal that exclusion cannot be justified. The chief deterrent function of the rule is its tendency to promote institutional compliance with the Fourth Amendment of the Constitution. Justice
John Paul Stevens
John Paul Stevens (April 20, 1920 – July 16, 2019) was an American lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1975 to 2010. At the time of his retirement, he was the second-oldes ...
filed a separate dissenting opinion.
Note
Arguing the case for the respondent was former
Los Angeles
Los Angeles ( ; es, Los Ángeles, link=no , ), often referred to by its initials L.A., is the largest city in the state of California and the second most populous city in the United States after New York City, as well as one of the world' ...
prosecutor and
ESPN
ESPN (originally an initialism for Entertainment and Sports Programming Network) is an American international basic cable sports channel owned by ESPN Inc., owned jointly by The Walt Disney Company (80%) and Hearst Communications (20%). The ...
legal analyst
Roger Cossack
Roger Lee Cossack is a former legal analyst for ESPN, CNN, TruTV, and a Distinguished Visiting Practitioner in Residence at Pepperdine University School of Law.
Biography
Cossack graduated with a B.A. from UCLA and then graduated with a J.D. from ...
.
See also
*
List of United States Supreme Court cases, volume 468
This is a list of all United States Supreme Court cases from volume 468 of the ''United States Reports
The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ord ...
*''
Olmstead v. United States
''Olmstead v. United States'', 277 U.S. 438 (1928), was a decision of the Supreme Court of the United States, on the matter of whether wiretapping of private telephone conversations, obtained by federal agents without a search warrant and subsequ ...
'' (1928)
*''
Mapp v. Ohio'' (1961)
*''
Aguilar v. Texas'' (1964)
*''
Spinelli v. United States Spinelli is an Italian surname. Notable people with the surname include:
* Altiero Spinelli (1907–1986), Italian advocate for European federalism and founding father of the European Union
* Anita Spinelli (1908-2010), Swiss artist and painter
...
'' (1969)
*''
Illinois v. Gates
''Illinois v. Gates'', 462 U.S. 213 (1983), is a Fourth Amendment case. ''Gates'' overruled '' Aguilar v. Texas'' and ''Spinelli v. United States'', thereby replacing the Aguilar–Spinelli test for probable cause with the "totality of the circum ...
'' (1983)
References
Further reading
*
*
External links
*
{{DEFAULTSORT:United States V. Leon
United States Supreme Court cases
United States Supreme Court cases of the Burger Court
United States Fourth Amendment case law
1984 in United States case law