Law School Case Brief
Illinois v. Krull - 480 U.S. 340, 107 S. Ct. 1160 (1987)
Unless a statute is clearly unconstitutional, a police officer cannot be expected to question the judgment of the legislature that passed the law. If the statute is subsequently declared unconstitutional, excluding evidence obtained pursuant to it prior to such a judicial declaration will not deter future violations under U.S. Const. amend. IV by an officer who has simply fulfilled his responsibility to enforce the statute as written.
Defendants Albert Krull and others operated an automobile wrecking yard. At that time, an Illinois statute required licensed motor vehicle and vehicular parts sellers to permit state officials to inspect certain required records. Pursuant to that statute, a police detective asked to see Krull' records of vehicle purchases. He was told that the records could not be located but was given a list of approximately five purchases. After receiving permission to look at the cars in the yard, the detective searched the premises and determined that three vehicles were stolen and that a fourth had had its identification number removed. He then seized the cars, and Krull and others were arrested for and charged with various crimes. At trial in Illinois state court, defendants filed a motion to suppress, which the trial court granted. The trial court ruled that, in accord with a federal-court ruling issued the day after the search, that the Illinois statute violated the Fourth Amendment because it permitted officers unbridled discretion in their warrantless searches. The Supreme Court of Illinois affirmed, rejecting the State's argument that the seized evidence was admissible because the detective had acted in good-faith reliance on the statute. The State was granted a writ of certiorari.
Was the evidence seized from the yard admissible against Krull and the other defendants?
The Supreme Court of the United States reversed the the judgment of the Supreme Court of Illinois and remanded the case to that court for further proceedings. The Court ruled that a good-faith exception to the Fourth Amendment exclusionary rule applied when, as in the instant case, an officer's reliance on the constitutionality of a statute was objectively reasonable, but the statute was subsequently declared unconstitutional. The Court noted that the statute was not clearly unconstitutional, and therefore, the detective was not expected to question the judgment of the legislature that passed the law.
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