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Law School Case Brief

Pa. Bd. of Prob. & Parole v. Scott - 524 U.S. 357, 118 S. Ct. 2014 (1998)

Rule:

Use of evidence obtained in violation of U.S. Const. amend. IV does not itself violate the Constitution. Rather, a U.S. Const. amend. IV violation is fully accomplished by the illegal search or seizure, and no exclusion of evidence from a judicial or administrative proceeding can cure the invasion of the defendant's rights which he has already suffered. The exclusionary rule is instead a judicially created means of deterring illegal searches and seizures. As such, the exclusionary rule does not proscribe the introduction of illegally seized evidence in all proceedings or against all persons, but applies only in contexts where its remedial objectives are thought most efficaciously served. Moreover, because the rule is prudential rather than constitutionally mandated, it is applicable only where its deterrence benefits outweigh its substantial social costs.

Facts:

Based on information that respondent Keith M. Scott, a parolee, had violated the conditions of his parole by such acts as possessing weapons, parole officers entered the former’s home and found firearms, a bow, and arrows. The evidence obtained during the search was admitted--over Scott’s objection that the search violated the prohibition, under the Federal Constitution's Fourth Amendment, against unreasonable searches and seizures--at Scott’s parole violation hearing, at which petitioner Pennsylvania Board of Probation and Parole recommitted the parolee to serve backtime. The Commonwealth Court of Pennsylvania, reversing the Board's decision, held that the search violated the Fourth Amendment and that the federal exclusionary rule, which generally prohibits the introduction at criminal trial of evidence obtained in violation of a defendant's Fourth Amendment rights, applied to the case. The Supreme Court of Pennsylvania, affirming the judgment of the Commonwealth Court, held that the search in question was unreasonable, and the exclusionary rule applied to the case because the officers who conducted the search were aware that Scott was a parolee. The Board sought review of the order. 

Issue:

Did the federal exclusionary rule of U.S. Const. amend. IV apply to the case at bar, where a parolee was found to have violated his parole based on evidence seized during an improperly conducted search?

Answer:

No.

Conclusion:

On writ of certiorari, the Supreme Court of the United States reversed the order that had affirmed the reversal of respondent's parole violation. The Court held that although the finding of a parole violation was based on evidence seized during an improper search, the exclusionary rule of  U.S. Const. amend. IV did not apply to parole revocation proceedings. According to the Court, the exclusionary rule did not extend to proceedings other than criminal trials. A parolee was not entitled to all due process rights to which a criminal defendant was entitled as the parole revocation proceedings adopted by the states were informal, administrative proceedings. The Court averred that the states had an overwhelming interest in maintaining informal, administrative parole revocation procedures, and application of the exclusionary rule would disrupt such proceedings. The deterrent effect of the exclusionary rule against unreasonable searches and seizures in parole revocation settings was marginal.

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