Case Brief Crim Pro 2020 United States v. Leon PDF

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United States v. Leon...

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Criminal Procedure Fall 2020 United States v. Leon (pg. 362 Dressler) Facts: The police received an anonymous tip that two individuals were selling drugs out of their apartment. Based on the information from the informant, the police started an investigation and eventually submitted an affidavit requesting a warrant to search three residences and automobiles. A facially valid search warrant was issued and pursuant to the warrant the police conducted their search. Leon (defendant) and the other defendants filed motions to suppress the evidence obtained pursuant to the search and the district court granted the motions, holding that the affidavit did not establish probable cause. The United States Supreme Court granted certiorari. Issue: Is evidence obtained in reasonable, good-faith reliance on a facially valid search warrant subject to the Fourth Amendment's exclusionary rule if the warrant is later deemed defective? Rule: Evidence obtained in reasonable, good-faith reliance on a facially valid search warrant is not subject to the Fourth Amendment's exclusionary rule, even if the warrant is later deemed defective. United States v. Leon (continued…) Analysis & Holding: No. Evidence obtained in reasonable, good-faith reliance on a facially valid search warrant is not subject to the Fourth Amendment's exclusionary rule, even if the warrant is later deemed defective. The exclusionary rule is not itself a constitutional right but is a judicial remedy intended to deter police from infringing on this constitutionally protected right by prohibiting the introduction of evidence that is obtained in violation of the Fourth Amendment. The rule developed because an individual’s constitutional rights are prioritized over efficient law enforcement. However, when the police reasonably rely on a facially valid search warrant, there is no improper police conduct to deter and therefore no Fourth Amendment interests are advanced by excluding the evidence. Therefore, the social cost of excluding the evidence outweighs any Fourth Amendment violation and the evidence must remain admissible at trial. Furthermore, while magistrates are given much deference in their probable cause determinations, their decisions are reviewable, as

is the information the police provide them with. The exclusionary rule is not intended to deter judges from unconstitutional actions, but instead acts as a deterrence to the police. Finally, where an officer knows or should know that the magistrate issuing a warrant has been mislead, or where an affidavit is so lacking in probable cause that no reasonable officer could reasonably rely on it, or where a warrant is so vague that no reasonable officer could assume it to be valid, the evidence obtained must be excluded. In this case, the officers reasonably relied on a facially valid warrant and the evidence obtained pursuant to the warrant is admissible even though the warrant was later held to be invalid. Concurrence (Blackmun): If the good-faith exception to the exclusionary rule that the Court here adopts leads police to contravene the Fourth Amendment, the Court’s decision will need to be reconsidered. Dissent (Brennan): The Court’s decision today all but destroys the Fourth Amendment protections against unreasonable searches and seizures. The exclusionary rule is not simply a judicial remedy and deterrent against unlawful police conduct, but the Fourth Amendment itself prohibits the use of illegally obtained evidence at trial. When the Court talks about the “cost” of the exclusionary rule, it is in fact complaining that the Fourth Amendment makes it harder to catch and try criminals. Furthermore, even assuming that the exclusionary rule was intended simply to deter abusive police conduct, evidence obtained in reasonable reliance on a warrant that is later found to be invalid should still be excluded or else the institutional incentive —to carefully provide probable cause in an affidavit and to review the warrant when it is issued—will be lost. Dissent (Stevens): The Fourth Amendment was created to protect people from the unreasonable issuance of warrants not grounded in probable cause. Therefore, the Court’s holding that the police’s reliance on a facially valid warrant is automatically appropriate, is unconstitutional....