Illinois v. Krull
480 U.S. 340 (1987)
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Rule of Law:
The Fourth Amendment exclusionary rule does not apply to evidence obtained by police officers who acted in objectively reasonable reliance upon a statute authorizing warrantless administrative searches, even if the statute is subsequently found to be unconstitutional.
Facts:
- The State of Illinois had a statutory scheme regulating automobile wrecking yards, which required licensees to maintain detailed records of vehicles and parts.
- The statute, in its 1981 form, authorized state officials to conduct warrantless inspections of a licensee's records and business premises 'at any reasonable time during the night or day' to verify the accuracy of the records.
- In 1981, Detective Leilan McNally of the Chicago Police Department went to Action Iron & Metal, Inc., an automobile wrecking yard operated by respondents Krull, Lucas, and Mucerino.
- Citing his authority under the statute, McNally asked to see the business's license and vehicle purchase records.
- Respondent Lucas could not produce the required documents but showed McNally a paper pad listing about five vehicle purchases.
- McNally then received permission from Lucas to look at the cars in the yard.
- Upon checking the serial numbers of several vehicles with his mobile computer, McNally determined that three were stolen and a fourth had its identification number removed.
- McNally seized the four vehicles and arrested Lucas; the other respondents were arrested later.
Procedural Posture:
- Respondents were charged with criminal violations in the Circuit Court of Cook County, Illinois, a state trial court.
- The trial court granted respondents' motion to suppress the seized evidence, ruling that the Illinois statute authorizing the search was unconstitutional.
- The State of Illinois, as appellant, appealed to the Appellate Court of Illinois, an intermediate appellate court.
- The Appellate Court vacated the suppression order and remanded the case, instructing the trial court to determine whether the officer acted in good faith.
- On remand, the trial court again granted the motion to suppress, concluding the good-faith exception does not apply to searches conducted under an unconstitutional statute.
- The State of Illinois, as appellant, appealed directly to the Supreme Court of Illinois, the state's highest court.
- The Supreme Court of Illinois affirmed the suppression order, holding that the good-faith exception does not extend to an officer's reliance on a statute authorizing warrantless searches.
- The United States Supreme Court granted certiorari to consider the issue.
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Issue:
Does the Fourth Amendment's exclusionary rule apply to evidence obtained by a police officer who acted in objectively reasonable reliance on a statute authorizing warrantless administrative searches, when that statute is later found to be unconstitutional?
Opinions:
Majority - Justice Blackmun
No. The Fourth Amendment's exclusionary rule does not apply when police act in objectively reasonable reliance on a statute that is later held unconstitutional. The primary purpose of the exclusionary rule is to deter police misconduct, not to punish the errors of legislators. There is no evidence that applying the rule would have a significant deterrent effect on legislatures, as their primary deterrent is the judicial power to invalidate unconstitutional statutes. An officer cannot be expected to question the judgment of the legislature that passed a law unless the statute is so clearly unconstitutional that a reasonable officer would have known of its defects. In this case, Detective McNally's reliance on the Illinois statute was objectively reasonable because the Court had previously upheld similar warrantless administrative search schemes for heavily regulated industries, and the statute's flaws were not obvious.
Dissenting - Justice O'Connor
Yes. The exclusionary rule should apply to evidence gathered pursuant to an unconstitutional statute. Historically, the Fourth Amendment was specifically created to protect against unreasonable searches authorized by legislative acts, such as the writs of assistance. Unlike neutral magistrates, legislators are subject to political pressures that may lead them to compromise Fourth Amendment rights to facilitate law enforcement. Creating a good-faith exception for unconstitutional statutes provides a 'grace period' that creates a positive incentive for legislatures to pass unconstitutional laws, knowing the evidence gathered will still be admissible. Furthermore, the standard created by the majority—that an officer must know a law is 'clearly' unconstitutional—is vague and will be difficult for courts to administer, ultimately chilling the litigation of Fourth Amendment claims.
Dissenting - Justice Marshall
Yes. Justice Marshall joined Justice O'Connor's dissent but wrote separately to state that he did not find it necessary to engage with the discussion of certain precedents cited in her opinion.
Analysis:
This case significantly expands the 'good-faith' exception to the exclusionary rule, first established for defective warrants in United States v. Leon. By extending the exception to cover an officer's reliance on a statute later found unconstitutional, the Court further shifted the exclusionary rule's focus from a remedy for individual defendants to a tool for deterring police misconduct only. This decision reinforces a cost-benefit analysis for applying the rule, weighing the societal cost of excluding reliable evidence against the limited deterrent effect on non-police actors like legislators. The ruling may reduce the incentive for criminal defendants to challenge the constitutionality of statutes, as they can no longer be certain of benefiting from a successful challenge through the suppression of evidence.
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