United States v. Leon
United States v. Leon is a significant Supreme Court case that addressed the balance between law enforcement practices and constitutional protections under the Fourth Amendment. The case arose when a state judge issued a search warrant based on an affidavit that referenced a confidential informant and police observations, leading to the discovery of illegal drugs in the residences of the suspects, including Alberto Leon. However, the court later ruled that the warrant lacked sufficient probable cause, resulting in the exclusion of the evidence found during the search.
In a 6-3 decision, the Supreme Court introduced the "good faith exception," which allows evidence to be admissible in court if law enforcement officers acted with an objectively reasonable belief that their search warrant was valid, even if it turns out to be flawed. Justice Byron R. White, who wrote the majority opinion, emphasized the need to avoid excessive disruption to the criminal justice system's ability to ascertain truth. The dissenting opinion from Justice William J. Brennan, Jr. focused on the importance of suppressing unconstitutionally obtained evidence, regardless of the intent behind the search. This ruling has had lasting implications, extending the good faith exception in subsequent cases, thereby influencing how law enforcement operates within the framework of constitutional rights.
On this Page
United States v. Leon
Date: July 5, 1984
Citation: 468 U.S. 897
Issue: Good faith exception
Significance: The Supreme Court ruled that the Fourth Amendment did not prohibit the admission of criminal evidence obtained from a search conducted pursuant to a warrant issued by a neutral and detached magistrate even if the warrant was ultimately found invalid through no fault of the police officers conducting the search.
Based on an affidavit referring to a confidential informant and various police observations, a state judge issued a search warrant authorizing police officers to search the residences of Alberto Leon and two other suspects. In the ensuing search, the police found large quantities of illegal drugs. At the trial, however, the court determined that the affidavit was insufficient to establish probable cause, and the evidence was thrown out.
By a 6-3 vote, the Supreme Court adopted the good faith exception, which stipulated that the exclusionary rule would not apply when the police were acting from an “objectively reasonable” belief that a search warrant is valid, even if the warrant later proves to be defective. Justice Byron R. White’s majority opinion warned of the social costs of excessive interference with the criminal justice system’s “truth-finding function,” and he insisted that the exclusionary rule was designed only as a deterrent to police misconduct, not to prevent judicial errors. In dissent, Justice William J. Brennan, Jr., argued that the Fourth Amendment requires the suppression of unconstitutionally seized evidence without any regard to its deterrent effect.
Although the Leon ruling was rather narrow, the Court subsequently extended the conditions for applying the good faith exception to the exclusionary rule. In Illinois v. Krull (1987), a 5-4 majority of the justices upheld the admission of evidence obtained in a warrantless search authorized by a statute that was later found unconstitutional. In Arizona v. Evans (1995), a 7-2 majority allowed the use of evidence found in a search resulting from police reliance on mistaken court records of outstanding arrest warrants.
Bibliography
Cruikshank, Catherine. "Dismantling the Exclusionary Rule: United States v. Leon and the Courts of Washington—Should Good Faith Excuse Bad Acts?" Seattle University Law Review 9.2 (1986): 415–39. Print.
Kanovitz, Jacqueline R. "The Exclusionary Rule." Constitutional Law. Philadelphia: Elsevier, 2012. 250–57. Print.
Kaye, David H. "Unraveling the Exclusionary Rule: From Leon to Herring to Robinson—and Back?" UCLA Law Review Discourse 58 (2010): 207–14. PDF file.
McInnis, Thomas N. The Evolution of the Fourth Amendment. Lanham: Lexington, 2009. Print.
"United States v. Leon." Legal Information Institute. Cornell U Law School, n.d. Web. 8 Jan. 2016.