Law School Case Brief
United States v. Leon - 468 U.S. 897, 104 S. Ct. 3405 (1984)
Reasonable minds frequently may differ on the question whether a particular affidavit establishes probable cause. The deference accorded to a magistrate's finding of probable cause does not preclude inquiry into the knowing or reckless falsity of the affidavit on which that determination was based. Courts must also insist that the magistrate purport to perform his neutral and detached function and not serve merely as a rubber stamp for the police. Reviewing courts will not defer to a warrant based on an affidavit that does not provide the magistrate with a substantial basis for determining the existence of probable cause. Sufficient information must be presented to the magistrate to allow that official to determine probable cause; his action cannot be a mere ratification of the bare conclusions of others.
Acting on the basis of information from a confidential informant, officers of the Burbank, Cal., Police Department initiated a drug-trafficking investigation involving surveillance of respondents' activities. Based on an affidavit summarizing the police officers' observations, Officer Rombach prepared an application for a warrant to search three residences and respondents' automobiles for an extensive list of items. The application was reviewed by several Deputy District Attorneys, and a facially valid search warrant was issued by a state-court judge. Ensuing searches produced large quantities of drugs and other evidence. Respondents were indicted for federal drug offenses, and filed motions to suppress the evidence seized pursuant to the warrant. After an evidentiary hearing, the District Court granted the motions in part, concluding that the affidavit was insufficient to establish probable cause. Although recognizing that Officer Rombach had acted in good faith, the court rejected the Government's suggestion that the Fourth Amendment exclusionary rule should not apply where evidence is seized in reasonable, good-faith reliance on a search warrant. The Court of Appeals affirmed, also refusing the Government's invitation to recognize a good-faith exception to the rule. The Government's petition for certiorari presented only the question whether a good-faith exception to the exclusionary rule should be recognized.
Did the Court of Appeals err in holding that there was no good faith exception to the U.S. Const. amend. IV exclusionary rule?
The U.S. Supreme Court reversed and held that the exclusionary rule should be modified to allow the admission of evidence seized in reasonable, good-faith reliance on a search warrant, even if the warrant was subsequently found to be defective. The Court held that suppression of evidence obtained pursuant to a warrant should be ordered only on a case-by-case basis and only in those unusual cases in which exclusion will further the purposes of the exclusionary rule; that the exclusionary rule should not be applied to deter objectively reasonable law enforcement activity; that the Fourth Amendment exclusionary rule does not bar the use in the prosecution's case-in-chief of evidence obtained by officers acting in reasonable reliance on a search warrant issued by a detached and neutral magistrate but ultimately found to be unsupported by probable cause; and that exclusion of the evidence in the present case on account of the magistrate's erroneous probable-cause determination was inappropriate because the affidavit related the results of an extensive investigation and provided evidence sufficient to create disagreement among thoughtful and competent judges as to the existence of probable cause.
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