Illinois v. Krull
**Illinois v. Krull Overview**
Illinois v. Krull is a significant Supreme Court case addressing the intersection of search and seizure laws and the exclusionary rule within the context of an administrative search. The case arose when Chicago police conducted a warrantless inspection of Action Iron & Metal, Inc. under a state law requiring businesses dealing with used automobile parts to maintain records and allow inspections. During this inspection, officers discovered several stolen vehicles, leading to criminal charges against the business owners. However, a federal court later ruled that the inspection statute was unconstitutional, prompting the trial court to deem the search illegal.
The Supreme Court ultimately reversed this decision, introducing the "good-faith" exception to the exclusionary rule. This legal principle allows evidence obtained from a search to be admissible if police officers acted under the reasonable belief that their actions were lawful based on existing statutes, even if those statutes are later found unconstitutional. The Court's ruling emphasized the need to balance the deterrence of unlawful police conduct against the importance of maintaining the integrity of the judicial process. The Krull case thus extends the good-faith exception, which was previously established in United States v. Leon, and has implications for future cases involving warrantless searches.
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Illinois v. Krull
The Case: U.S. Supreme Court ruling on search and seizure
Date: Decided on March 9, 1987
Significance: In this case, the Supreme Court held that the “good-faith exception,” sometimes allowing the courtroom use of evidence seized illegally, could apply to certain warrantless searches.
Illinois businesses that buy and sell used automobile parts or that process automobile scrap metal were required by a 1981 statute to obtain a business license, maintain detailed records of their transactions, and make these records and the business premises available to the state for inspection at any reasonable time to determine the accuracy of the records. On July 5, 1981, the Chicago police entered the premises of Action Iron & Metal, Inc., an automobile wrecking yard, to inspect its records and examine the vehicle identification numbers of cars in the yard. The clerk at the wrecking yard was unable to produce any records other than a paper pad on which approximately five vehicle purchases were listed. The inspection of the wrecking yard disclosed that three of the cars were stolen and a fourth car had no vehicle identification number. Two men (Krull, who held the license for Action Iron & Metal, Inc., and the clerk) were charged with various criminal violations of the Illinois motor vehicle statutes.
On July 6, 1981, a federal court held that the Illinois statute was an unconstitutional administrative search law. Based on this decision, the Illinois trial court held that the search was illegal. The Illinois trial court also held that the United States v. Leon (1984) good-faith exception to the exclusionary rule did not apply because it was limited to circumstances in which a search warrant was issued by a neutral magistrate. The Illinois Supreme Court affirmed the trial court’s decision. The U.S. Supreme Court, however, in a 5-4 vote, reversed the decision. It stated that the Leon good-faith exception to the exclusionary rule could apply when a police officer’s reliance on the constitutionality of a statute authorizing the search was objectively reasonable, even though the statute is subsequently declared unconstitutional.
In Justice Harry Blackmun’s majority opinion, the Court noted that Leon had reaffirmed that the purpose of the exclusionary rule is to deter future unlawful police conduct, not to provide a cure for past unlawful police conduct. Because the exclusion of evidence undermines the truth-finding process of a criminal trial, the exclusionary rule remedy should be imposed only when the likelihood of deterring future unlawful police conduct outweighs the cost to the criminal justice system’s primary purpose: determining the guilt or innocence of a defendant.
The statutory authorization for the warrantless search functions like the warrant for three reasons, the Court said. First, there is no evidence that legislators ignored the requirements of the Fourth Amendment in passing such legislation. Second, members of the legislature, like neutral magistrates, have no direct stake in the day-to-day conduct of law enforcement, so there is little incentive for them to overstep the limits of the Fourth Amendment. Third, no proof was offered that the application of the exclusionary rule would deter legislators from enacting statutes that may be declared unconstitutional or that exclusion of evidence in these cases will significantly deter future unlawful police conduct. Therefore, any marginal deterrent benefit in applying the exclusionary rule to cases such as this is outweighed by the cost of excluding reliable and relevant evidence from the process of determining guilt.
In this case, the police acted in a reasonable manner in relying on the statute as authorizing a lawful search, because the Supreme Court had approved warrantless administrative searches in similar cases. In closing, the Court limited its decision by noting that if there was proof that the legislature wholly abandoned its responsibility to enact constitutional laws under the Fourth Amendment, or if a reasonable officer should have known the statute was unconstitutional, then the exclusionary rule should apply. Despite the caveat at the close of the opinion, the Krull case significantly expanded the scope of the decision in Leon by leaving open the possibility that it could be applied to other warrantless search circumstances.