Summary of United States v. Leon 468 U.S. 897 (1984).

Statement of the case: The D held that there was no good faith exception to the Fourth Amendment exclusionary rule.

Procedure below: Petitioner appealed the decision of the United States Court of Appeals for the Ninth Circuit.

Statement of the facts: Police officers initiated surveillance of Leon’s (D) activities. A search warrant was issued pursuant to that surveillance. A large quantity of drugs were seized. D was charged with violations of federal drug-trafficking laws. At trial, the court granted D’s suppression motion because the warrant was not issued on probable cause. Specifically, the court found that the warrant contained allegations of an untested informant and limited corroboration by the police. The court of appeals affirmed; they refused to accept a good faith exception to the exclusionary rule. The Supreme Court granted certiorari.

Legal issue: Should the 4th Amendment’s exclusionary rule be modified so as not to bar the use of evidence obtained by officers acting in reasonable reliance on a search warrant issued by a detached and neutral magistrate but ultimately found to be unsupported by probable cause?

Holding: The 4th Amendment’s exclusionary rule should be modified to permit the introduction of evidence obtained in the reasonable good-faith belief that a search or seizure was in accord with the 4th Amendment.

Reasoning: (White, Justice) Yes. The 4th Amendment’s exclusionary rule should be modified to permit the introduction of evidence obtained in the reasonable good-faith belief that a search or seizure was in accord with the 4th Amendment. The officer’s reliance on the warrant must be objectively reasonable. The exclusionary rule is not a personal constitutional right. It is a judicially created remedy intended to safeguard 4th Amendment rights through its deterrent effect. Therefore, the costs and benefits of excluding inherently trustworthy tangible evidence must be weighed, and the remedy applied only where its costs are acceptable and its deterrent effect is well served. The rule’s chief benefit is to deter police misconduct, not to punish judicial errors. No evidence has been shown that relaxing the rule would decrease a judge’s professional commitment to protecting 4th Amendment rights. Courts may allow a good-faith exception to the exclusionary rule. Good faith is an exception to the exclusionary rule. The exclusionary rule is a judicially created rule designed to deter police misconduct. The rule should not be applied when it does not serve its function. If a police officer in good faith relies on a defective warrant, he is not guilty of misconduct. To suppress evidence when a warrant is defective does nothing to deter future misconduct, because there is nothing the officer should have done differently. The purposes of the exclusionary rule are not achieved by suppressing evidence obtained in good faith reliance on a defective search warrant. Reversed.

Concurring: (Blackmun, Justice) The exclusionary rule is not constitutionally compelled and there is no way to avoid the majority decision because the rule has not appreciable effect when officers act in objectively reasonable reliance upon search warrants.

Dissent: (Brennan, Justice) The courts use of costs and benefits analysis has a narcotic effect of creating the illusion of technical precision and ineluctability. The majority has not given honest assessment to the merits of the exclusionary rule. If this good faith exception weakens police compliance with the 4th Amendment, then this exception will be reconsidered in the future.

Critical summary: The exclusionary rule is a judge made rule created to deter police misconduct; it is intended to deter 4th Amendment misconduct by the government as a whole, not just excesses by the police. Neither the history nor the language of the 4th Amendment suggests that it was intended to restrict the police but allow other agents of the same government to take advantage of unlawfully seized evidence. When does a judge made rule come under the penumbra of rights inherent in the constitution? This rule should be part of the inherent rights in the constitution. Good faith is the current standard for applying the exclusionary rule. Exceptions: 4 circumstances when the evidence will be excluded notwithstanding the fact that the officer acted in good faith. 1) If the magistrate issued a warrant by relying on affidavit supplied by affiant who knew that statements were false or recklessly disregarded the truth. Generally speaking that magistrate must assume officer is saying the truth because he is under oath. In this situation we have bad faith and needs to be deterred. 2) If issuing magistrate abandoned neutral and detached role by blindly rubber stamping behavior of police. Reasonable officer must realize that this behavior is unethical. 3) If warrant is completely lacking in any indicia of probable cause than there is no good faith on part of police officer. 4) If police officer relies on warrant that is facially deficient. If it looks like a preconstitution general warrant lacking all particularities.