United States v. Leon
Encyclopedia
United States v. Leon, 468 U.S. 897
(1984), was a search and seizure
case in which the Supreme Court of the United States
created the "good faith
" exception to the exclusionary rule
.
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
and information from a second informant, a detective wrote an affidavit
and a judge
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.
was made applicable to individual states in 1961's case, Mapp v. Ohio
. The exclusionary rule
, which forbids the use of evidence obtained through illegal search in a criminal trial, is "neither intended nor able to 'cure the invasion of the defendant's rights which he has already suffered.'" Justice Byron White
states that the Court has previously defined the limits of the exclusionary rule and that there is therefore good reason to do so in this case. The exclusionary rule was designed to deter unlawful police action, not punish the errors of magistrate
s. There is no evidence that judges and magistrates are more likely to ignore suspects' Fourth Amendment rights. White also states that there is no evidence that the exclusion of evidence will deter magistrates from issuing unsound warrants.
White clarifies that suppression of evidence should continue in cases where the magistrate was misled by information supplied in an affidavit in "bad faith". As long as the person writing the affidavit wrote it in good faith, the decision is that of the magistrate and the exclusionary rule serves no useful function. The officers enforcing the warrant must be able to rely on the decision of the magistrate.
Arguing the case for the respondent was former Los Angeles
prosecutor and now-ESPN
legal analyst Roger Cossack
.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1984), was a search and seizure
Search and seizure
Search and seizure is a legal procedure used in many civil law and common law legal systems whereby police or other authorities and their agents, who suspect that a crime has been committed, do a search of a person's property and confiscate any relevant evidence to the crime.Some countries have...
case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
created the "good faith
Good-faith exception
In United States constitutional law, the good-faith exemption is a legal doctrine providing an exemption to the exclusionary rule....
" exception to the exclusionary rule
Exclusionary rule
The exclusionary rule is a legal principle in the United States, under constitutional law, which holds that evidence collected or analyzed in violation of the defendant's constitutional rights is sometimes inadmissible for a criminal prosecution in a court of law...
.
Background
In August 1981, police in Burbank, CaliforniaBurbank, California
Burbank is a city in Los Angeles County in Southern California, United States, north of downtown Los Angeles. The estimated population in 2010 was 103,340....
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
Surveillance is the monitoring of the behavior, activities, or other changing information, usually of people. It is sometimes done in a surreptitious manner...
and information from a second informant, a detective wrote an affidavit
Affidavit
An affidavit is a written sworn statement of fact voluntarily made by an affiant or deponent under an oath or affirmation administered by a person authorized to do so by law. Such statement is witnessed as to the authenticity of the affiant's signature by a taker of oaths, such as a notary public...
and a judge
Judge
A judge is a person who presides over court proceedings, either alone or as part of a panel of judges. The powers, functions, method of appointment, discipline, and training of judges vary widely across different jurisdictions. The judge is supposed to conduct the trial impartially and in an open...
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.
Arguments
Exclusion of evidence obtained by the police in violation of the Fourth AmendmentFourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
was made applicable to individual states in 1961's case, Mapp v. Ohio
Mapp v. Ohio
Mapp v. Ohio, , was a landmark case in criminal procedure, in which the United States Supreme Court decided that evidence obtained in violation of the Fourth Amendment, which protects against "unreasonable searches and seizures," may not be used in criminal prosecutions in state courts, as well as...
. The exclusionary rule
Exclusionary rule
The exclusionary rule is a legal principle in the United States, under constitutional law, which holds that evidence collected or analyzed in violation of the defendant's constitutional rights is sometimes inadmissible for a criminal prosecution in a court of law...
, which forbids the use of evidence obtained through illegal search in a criminal trial, is "neither intended nor able to 'cure the invasion of the defendant's rights which he has already suffered.'" Justice Byron White
Byron White
Byron Raymond "Whizzer" White won fame both as a football halfback and as an associate justice of the Supreme Court of the United States. Appointed to the court by President John F. Kennedy in 1962, he served until his retirement in 1993...
states that the Court has previously defined the limits of the exclusionary rule and that there is therefore good reason to do so in this case. The exclusionary rule was designed to deter unlawful police action, not punish the errors of magistrate
Magistrate
A magistrate is an officer of the state; in modern usage the term usually refers to a judge or prosecutor. This was not always the case; in ancient Rome, a magistratus was one of the highest government officers and possessed both judicial and executive powers. Today, in common law systems, a...
s. There is no evidence that judges and magistrates are more likely to ignore suspects' Fourth Amendment rights. White also states that there is no evidence that the exclusion of evidence will deter magistrates from issuing unsound warrants.
White clarifies that suppression of evidence should continue in cases where the magistrate was misled by information supplied in an affidavit in "bad faith". As long as the person writing the affidavit wrote it in good faith, the decision is that of the magistrate and the exclusionary rule serves no useful function. The officers enforcing the warrant must be able to rely on the decision of the magistrate.
Arguing the case for the respondent was former Los Angeles
Los Ángeles
Los Ángeles is the capital of the province of Biobío, in the commune of the same name, in Region VIII , in the center-south of Chile. It is located between the Laja and Biobío rivers. The population is 123,445 inhabitants...
prosecutor and now-ESPN
ESPN
Entertainment and Sports Programming Network, commonly known as ESPN, is an American global cable television network focusing on sports-related programming including live and pre-taped event telecasts, sports talk shows, and other original programming....
legal analyst Roger Cossack
Roger Cossack
Roger Cossack is currently a legal analyst for ESPN, TruTV, and a Distinguished Visiting Professor at Pepperdine University School of Law. Cossack graduated from UCLA and UCLA School of Law and worked as a prosecutor in Los Angeles County, California. Cossack also argued in front of the United...
.
See also
- List of United States Supreme Court cases, volume 468
- Olmstead v. United StatesOlmstead v. United StatesOlmstead v. United States, , was a decision of the Supreme Court of the United States, in which the Court reviewed whether the use of wiretapped private telephone conversations, obtained by federal agents without judicial approval and subsequently used as evidence, constituted a violation of the...
(1928) - Mapp v. OhioMapp v. OhioMapp v. Ohio, , was a landmark case in criminal procedure, in which the United States Supreme Court decided that evidence obtained in violation of the Fourth Amendment, which protects against "unreasonable searches and seizures," may not be used in criminal prosecutions in state courts, as well as...
(1961) - Aguilar v. TexasAguilar v. TexasAguilar v. Texas, 378 U.S. 108 , was a decision by the United States Supreme Court, which held that “[a]lthough an affidavit supporting a search warrant may be based on hearsay information and need not reflect the direct personal observations of the affiant, the magistrate must be informed of some...
(1964) - Spinelli v. United States (1969)
- Harris v. New York (1971)
- Illinois v. GatesIllinois v. GatesIllinois v. Gates, , 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 circumstances" test....
(1983)