United States v. Leon

United States v. Leon Case Brief

United States Supreme Court
468 U.S. 897 (1984)

ISSUE: Should the 4th Amdt. Exclusionary Rule be modified so as to not bar the admission of evidence seized in reasonable, good-faith reliance on a search warrant that is subsequently held to be defective?
HOLDING: No.
FACTS:
  • Officer Rombach applied for a search warrant for the three houses and the cars belonging to Ds for an extensive list of things, which was partially supported by a CI of unproven reliability
  • Magistrate issued the warrant, and large quantities of drugs were found at 2 of the houses and some at the other
PROCEDURAL HISTORY:
  • Ds moved to suppress the evidence seized pursuant to the warrant
  • Dist. Ct. granted motions in part insofar as each D only had standing to object to the drugs found in his own house
    • Affidavit insufficient to establish PC
    • Officer Rombach had acted in good faith
    • Denied motion for reconsideration
  • Ninth Circuit affirmed
REASONING:
  • *Good faith exception: Evaluation of the costs and benefits of suppressing reliable physical evidence seized by officers reasonably relying on a warrant issued by a neutral and detached magistrate leads to the conclusion that such evidence should be admissible in the prosecution's case-in-chief
    • Reliance upon a warrant will normally establish that the officer has acted in good faith
    • Reliance must be objectively reasonable
  • Exclusion inappropriate: No basis for believing that exclusion of evidence seized pursuant to a warrant will have a significant deterrent effect on the issuing judge or magistrate, as they have no stake in the outcome
    • Exclusionary Rule is designed to deter police misconduct rather than to punish the errors of judges and magistrates
    • There exists no evidence suggesting the judges and magistrates are inclined to ignore or subvert the 4th Amdt. or that lawlessness among these actors requires application of the extreme sanction of exclusion
  • When exception won't apply:
    • Magistrate or judge was misled by info in the affidavit that the affiant knew was false or would have known was false but for reckless disregard for the truth
    • Magistrate wholly abandoned his judicial role
    • Where a warrant is so facially deficient that no reasonable officers could reasonably presume it to be valid
COMMENTS:
  • Rule: If the officers reasonably relied in good faith on authorization by a neutral & detached magistrate, there will be no Exclusionary Rule applied
    • Rule only meant to deter police misconduct, not judicial errors
    • What could be deterred: Lack of due diligence in police investigations & lack of diligence by magistrates
  • Exceptions: Good faith exception won't apply where there's:
    • Lies in affidavits
    • Absolutely no PC (e.g., anonymous tips alonew/o corroboration or supporting evidence (Florida v. J.L.))
    • No particularity (facially deficient)

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