United States v. Leon
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| United States v. Leon | |||||||||||||
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| Argued January 17, 1984 Decided July 5, 1984 |
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| Holding | |||||||||||||
| Established that evidence obtained in good faith by police relying upon a search warrant that subsequently is found to be deficient may be used in a criminal trial. | |||||||||||||
| Court membership | |||||||||||||
| Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Byron White, Thurgood Marshall, Harry Blackmun, Lewis Franklin Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor |
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| Case opinions | |||||||||||||
| Majority by: White Joined by: Burger, Blackmun, Powell, Rehnquist, O'Connor Concurrence by: Blackmun Dissent by: Brennan Joined by: Marshall Dissent by: Stevens |
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| Laws applied | |||||||||||||
| U.S. Const. amend. IV | |||||||||||||
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.
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[edit] Background
In 1981, police in Burbank, California 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.
[edit] Arguments
The exclusionary rule (which forbids evidence obtained through illegal search and seizure from admittance in criminal trial) is "neither intended nor able to 'cure the invasion of the defendant's rights which he has already suffered.'" He 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 magistrates. There is no evidence that judges and magistrates are inclined 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.
[edit] External links
[edit] Bibliography
- Hemmens C, Worrall JL, Thompson A. Criminal Justice Case Briefs: Significant Cases in Criminal Procedure. Los Angeles: Roxbury Publishing, 2004. ISBN 1-931719-23-3
