Law School Case Brief
Davis v. United States - 564 U.S. 229, 131 S. Ct. 2419 (2011)
It is one thing for the criminal to go free because the police blundered. It is quite another to set the criminal free because the constable has scrupulously adhered to governing law. Excluding evidence in such cases deters no police misconduct and imposes substantial social costs. When the police conduct a search in objectively reasonable reliance on binding appellate precedent, the exclusionary rule does not apply.
While conducting a routine vehicle stop, police arrested petitioner Willie Davis, a passenger, for giving a false name. After handcuffing Davis and securing the scene, the police searched the vehicle and found Davis' revolver. Davis was then indicted on charges of being a felon in possession of a firearm. In a suppression motion, Davis acknowledged that the search of the vehicle complied with existing Eleventh Circuit precedent interpreting New York v. Belton, 453 U.S. 454, 101 S. Ct. 2860, 69 L. Ed. 2d 768, but Davis raised a Fourth Amendment challenge to preserve the issue on appeal. The District Court denied the motion, and Davis was convicted. While his appeal was pending, this Court announced, in Arizona v. Gant, 556 U.S. 332, 343, 129 S. Ct. 1710, 173 L. Ed. 2d 485, a new rule governing automobile searches incident to arrests of recent occupants. The Eleventh Circuit held, under Gant, that the vehicle search at issue violated Davis' Fourth Amendment rights, but the court declined to suppress the revolver and affirmed Davis' conviction.
Was the search conducted subject to the exclusionary rule?
The U.S. Supreme Court held that, while the search violated the Fourth Amendment under its new precedent, the exclusionary rule did not apply to require suppression of the firearm since the police conducted the search in objectively reasonable reliance on existing and binding judicial precedent. The sole purpose of the exclusionary rule was to deter deliberate or reckless disregard for Fourth Amendment rights, the police acted with an objectively reasonable and good-faith belief that their conduct was lawful, and the exclusionary rule did not require deterrence of such conduct. Further, while the new precedent applied retroactively to the defendant during his appeal, the exclusionary rule did not automatically apply to the unconstitutional search since the purpose of the rule was not advanced by suppression.
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