United States v. Thomas James Savoca
761 F.2d 292, 1985 U.S. App. LEXIS 31065 (1985)
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Rule of Law:
Under the good faith exception established in United States v. Leon, evidence obtained by law enforcement officers acting in objectively reasonable reliance on a search warrant issued by a detached and neutral magistrate will not be suppressed, even if the warrant is subsequently found to be unsupported by probable cause.
Facts:
- Thomas Savoca and James Carey were suspects in several bank robberies that occurred in northeast Ohio and northwest Pennsylvania.
- Federal arrest warrants were issued for Savoca and Carey for a bank robbery in Austintown, Ohio.
- FBI agents in Phoenix, Arizona, located the suspects and, according to the affidavit for a search warrant, observed them in Room 135 of a motel.
- The bank robberies occurred over 2,000 miles away from the Phoenix motel room.
- The affidavit supporting the search warrant for the motel room did not state when the bank robberies had occurred, failing to establish timeliness.
- The affidavit also failed to describe the relationship of the suspects to the premises, other than that they had been 'seen' there.
- FBI agents arrested Savoca and Carey in Phoenix and searched the motel room pursuant to the warrant.
Procedural Posture:
- Thomas Savoca was convicted of bank robbery in a U.S. District Court, which served as the trial court.
- Savoca, as appellant, appealed his conviction to the U.S. Court of Appeals for the Sixth Circuit.
- The Court of Appeals initially reversed Savoca's conviction, holding that the search warrant used to obtain key evidence was not supported by probable cause.
- The government, as appellee, petitioned the Court of Appeals for a rehearing.
- The Court of Appeals granted the government's petition for rehearing to reconsider the case in light of the Supreme Court's recent decision in United States v. Leon.
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Issue:
Does the good faith exception to the exclusionary rule prevent the suppression of evidence obtained pursuant to a search warrant that was later ruled invalid for failing to establish a sufficient nexus between the alleged crimes and the place to be searched?
Opinions:
Majority - Contie, J.
Yes. The good faith exception prevents the suppression of the evidence because the officers' reliance on the warrant was objectively reasonable. Although the court reaffirms its prior conclusion that the warrant was invalid for lack of probable cause, the Supreme Court's recent decision in United States v. Leon requires a different outcome regarding suppression. The exclusionary rule's purpose is to deter police misconduct, not to punish judicial errors. The court must determine whether a 'reasonably well-trained officer would have known that the search was illegal despite the magistrate’s authorization.' While the legal principle requiring a nexus between the crime and the place to be searched is well-established, the factual gradations in probable cause cases are often subtle. Because precedent is not always clear-cut and different courts have upheld warrants on similarly skeletal information, a reasonable officer could have concluded that this warrant was valid. Therefore, the affidavit was not 'so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable,' and the evidence is admissible under the Leon good faith exception.
Dissenting - Jones, J.
No. The good faith exception does not apply because the warrant was based on an affidavit so lacking in indicia of probable cause that any official belief in its validity was entirely unreasonable. This case falls squarely into one of the four exceptions to the Leon good faith rule. The legal principle that a suspect's mere presence at a location does not establish probable cause to search it is clear, well-established, and something a reasonably well-trained officer is charged with knowing. The affidavit here provided no nexus between the crimes and the motel room; it was remote in both time and distance from the robberies and offered no facts linking evidence to the location. The cases cited by the majority to show ambiguity are all distinguishable, as they contained additional facts supporting a nexus. An officer's reliance on such a facially deficient affidavit is objectively unreasonable, and therefore the exclusionary rule should apply to suppress the evidence.
Analysis:
This case is a significant early application of the Supreme Court's landmark decision in United States v. Leon, demonstrating how federal appellate courts would interpret the 'objectively reasonable' standard of the good faith exception. The decision illustrates that the exception can save evidence seized under a warrant even when that warrant clearly violates existing circuit precedent (United States v. Hatcher). It suggests that as long as the question of probable cause is arguably debatable, even if ultimately incorrect, an officer's reliance on the magistrate's authorization will likely be deemed reasonable, thus narrowing the practical application of the exclusionary rule and making it more difficult for defendants to suppress evidence.
