United States v. Leon
468 U.S. 897, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984)
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Rule of Law:
The Fourth Amendment exclusionary rule does not bar the use of evidence obtained by officers acting in objectively reasonable reliance on a search warrant issued by a detached and neutral magistrate, even if the warrant is later found to be unsupported by probable cause.
Facts:
- In August 1981, a confidential informant told an officer of the Burbank Police Department that Armando Sanchez and Patsy Stewart were selling cocaine and methaqualone from their residence at 620 Price Drive in Burbank, California, and stored other drugs elsewhere.
- The informant also stated he had witnessed a sale of methaqualone by Patsy Stewart at the residence approximately five months earlier and observed a shoebox containing a large amount of cash belonging to her.
- Burbank police initiated an extensive investigation, observing activity at the Price Drive residence, linking cars there to Sanchez (previous marihuana arrest) and Stewart (no criminal record), and observing Ricardo Del Castillo (previous marihuana arrest) visit the residence and leave with a small paper sack.
- Officers linked Del Castillo to Alberto Leon (previous drug arrest), learning from a Glendale police officer that an informant had stated Leon stored a large quantity of methaqualone at his residence at 716 South Sunset Canyon in Burbank.
- Police observed additional suspicious activity at the Price Drive residence, the Sunset Canyon residence, and a condominium at 7902 Via Magdalena, as well as involving the respondents' automobiles, and saw Sanchez and Stewart travel to Miami and return to Los Angeles.
- Officer Cyril Rombach, an experienced narcotics investigator, prepared a comprehensive application for a warrant to search the three residences and respondents' automobiles for drug-trafficking items, which was reviewed by several Deputy District Attorneys.
- A state Superior Court Judge issued a facially valid search warrant based on Officer Rombach's application.
- The ensuing searches produced large quantities of drugs at the Via Magdalena and Sunset Canyon addresses, a small quantity at the Price Drive residence, and other evidence at each residence and in Stewart's and Del Castillo's automobiles.
Procedural Posture:
- Armando Sanchez, Patsy Stewart, Ricardo Del Castillo, and Alberto Leon were indicted by a grand jury in the District Court for the Central District of California on charges of conspiracy to possess and distribute cocaine and various substantive counts.
- Respondents filed motions to suppress the evidence seized pursuant to the warrant in the District Court.
- The District Court held an evidentiary hearing and granted the motions to suppress in part, concluding that the affidavit was insufficient to establish probable cause but acknowledging that Officer Rombach had acted in good faith.
- The District Court denied the Government's motion for reconsideration.
- A divided panel of the Court of Appeals for the Ninth Circuit affirmed the District Court's suppression order, concluding that Officer Rombach's affidavit failed to establish probable cause under Aguilar-Spinelli and Spinelli and refusing to recognize a good-faith exception to the Fourth Amendment exclusionary rule.
- The Government petitioned the Supreme Court for certiorari, explicitly declining to seek review of the lower courts’ probable cause determinations and presenting only the question of whether the exclusionary rule should be modified to admit evidence seized in reasonable, good-faith reliance on a defective warrant.
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Issue:
Does the Fourth Amendment exclusionary rule prohibit the admission of evidence obtained by police officers who acted in objectively reasonable reliance on a search warrant that was subsequently found to be invalid due to a lack of probable cause?
Opinions:
Majority - Justice White
No, the Fourth Amendment exclusionary rule does not bar the admission of evidence obtained by police officers who acted in objectively reasonable reliance on a search warrant, even if the warrant is subsequently found to be invalid due to a lack of probable cause. The exclusionary rule is a "judicially created remedy designed to safeguard Fourth Amendment rights generally through its deterrent effect, rather than a personal constitutional right of the party aggrieved." Its application is subject to a cost-benefit analysis. The marginal benefits of suppressing evidence obtained by officers who acted in objective good faith on a warrant are minimal, as such officers are not engaging in misconduct to deter. Penalizing an officer for a magistrate’s error, rather than his own, does not logically deter Fourth Amendment violations. Judges and magistrates are neutral judicial officers with no stake in criminal prosecutions, so excluding evidence has little deterrent effect on their conduct. However, the good-faith exception does not apply in four situations: (1) if the magistrate was misled by information in an affidavit that the affiant knew was false or would have known was false but for reckless disregard of the truth; (2) if the issuing magistrate wholly abandoned his judicial role; (3) if the affidavit was so "bare bones" as to render official belief in probable cause entirely unreasonable; or (4) if the warrant was so facially deficient (e.g., in particularizing the place or items to be seized) that executing officers could not reasonably presume it to be valid. In this case, Officer Rombach's affidavit was not "bare bones" and was sufficient to create disagreement among judges as to probable cause, making the officers' reliance objectively reasonable.
Dissenting - Justice Brennan
No, the Fourth Amendment exclusionary rule should not be modified to allow evidence obtained under a subsequently invalidated warrant, even if officers acted in good faith. The exclusionary rule is not merely a "judicially created remedy" based on deterrence, but a direct constitutional command, an "essential part of both the Fourth and Fourteenth Amendments." By admitting illegally seized evidence, the judiciary becomes complicit in the governmental action prohibited by the Amendment. The Court's cost-benefit analysis is flawed; the "cost" of lost evidence is the price society pays for the privacy safeguarded by the Fourth Amendment itself. Empirical data shows that the actual costs of the exclusionary rule (in terms of lost prosecutions) are quite low, while its benefits in promoting institutional compliance by law enforcement agencies are significant. Allowing a "reasonable mistake" exception will undermine this institutional deterrence, encouraging police departments to be less diligent in training officers and securing proper warrants, and promoting "magistrate shopping." It will also convey a message to magistrates that their warrant decisions are insulated from meaningful review, reducing their incentive to meticulously scrutinize applications. Furthermore, given the relaxed probable cause standard from Illinois v. Gates, it is "virtually inconceivable" that a warrant could be invalid under Gates yet objectively reasonable for police to rely upon, leading to the "mind-boggling concept of objectively reasonable reliance upon an objectively unreasonable warrant."
Concurring - Justice Blackmun
Yes, the Court correctly holds that the exclusionary rule does not apply when officers reasonably rely on a faulty search warrant. The decision is based on an empirical judgment that the rule has little deterrent effect when officers act in objectively reasonable reliance on search warrants. This empirical judgment, while provisional, is reasonable based on current information. However, the Court must be prepared to reconsider its decision if, over time, experience demonstrates that this "good-faith exception" leads to a material decrease in police compliance with Fourth Amendment requirements.
Concurring - Justice Stevens
No, an official search and seizure cannot be both "unreasonable" (due to lack of probable cause) and "reasonable" (due to officer good faith) at the same time, and thus the evidence in Leon should be suppressed. The Fourth Amendment's two clauses — prohibiting unreasonable searches and seizures, and requiring warrants to be based on probable cause and particularity — must be read together. If a warrant lacks probable cause, the ensuing search is by definition constitutionally unreasonable. The Framers were deeply suspicious of warrants issued without probable cause, seeing them as instruments of oppressive searches. Therefore, it has never been "reasonable" for police to rely solely on the mere fact that a warrant has issued if they failed to provide sufficient information to the magistrate. The Court's new "double standard of reasonableness" undermines the deterrent function of the exclusionary rule, encouraging officers to seek warrants even when probable cause is doubtful, and tarnishes the judiciary's role by making courts complicit in constitutional violations without providing a remedy. The Constitution demands a remedy for its violation, not merely an unenforced honor code.
Analysis:
United States v. Leon fundamentally reshaped Fourth Amendment jurisprudence by introducing the "objective good faith" exception to the exclusionary rule. This decision significantly limits the application of the rule, shifting its focus from a broad constitutional mandate to primarily a deterrent against police misconduct. While proponents argue it prevents the release of guilty defendants due to minor technical errors, critics contend it weakens judicial oversight of law enforcement and may incentivize less rigorous probable cause determinations by both officers and magistrates. The ruling provides greater flexibility for law enforcement but places a higher burden on defendants to prove police misconduct egregious enough to warrant suppression, rather than simply demonstrating a Fourth Amendment violation.
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