United
States
v.
Leon
Et Al. Decided July 5, 1984
(Cite
as:468 U.S. 897)
Facts: Officers of Burbank,
CA Police Department commenced a drug-trafficking investigation, based on the
information of a confidential informant, that involved the surveillance of the
respondents' activities (United States v. Leon - 468 U.S.
897 (1984)). Based upon a summarizing affidavit of the
officer's observations, an application for a warrant to search three residents
and the owners vehicles was put together by Officer Rombach and reviewed by a
number of Deputy District Attorneys where a state court judge issued a valid
search warrant (United States v. Leon - 468 U.S. 897 (1984)). With this warrant, the following searches
found large amounts of drugs and other evidence therefore, the respondents'
were charged with federal drug offenses who, in return, filed motions to
suppress the evidence that was seized under the warrant (United States v. Leon - 468 U.S. 897 (1984)). The district court granted the respondents'
motions to dismiss partly because the affidavit did not supply sufficient
probable cause, however, the court did recognize that Officer Romback had acted
in good faith, but "the court rejected the Government's suggestion that
the Fourth Amendment exclusionary rule should not apply where evidence seized
in reasonable, good faith reliance on a search warrant" (United States
v. Leon - 468 U.S. 897 (1984)). The Court of Appeals agreed as well and
affirmed, refusing to budge on the Government's request to identify a good
faith exception to the rule.
Issue: The issue in this
case is whether the evidence obtained under the issued search warrant, that was
issued by a neutral and detached judge, should be excluded due to the warrant
ultimately being found unsupported by probable cause (United States v. Leon - 468 U.S. 897 (1984))?
Holding: It was acknowledged
by the Supreme Court that the police used an invalid search warrant to obtain
their evidence against Leon but the court ruled against Leon by permitting a
good faith exception to the exclusionary rule saying that "the
exclusionary rule can be modified somewhat without jeopardizing its ability to
perform its intended functions" (United States v. Leon - 468 U.S. 897 (1984)). The majority opinion was filed by Justice
Byron White who answered the above question with a resounding no, explaining
that "only when a warrant is grounded upon an affidavit knowingly or
recklessly false has the Supreme Court of the United States suppressed the
evidence obtained as a result" (United States v. Leon, 2013). The aforementioned reference goes on to
point out that "the exclusionary rule is designed to deter police
misconduct rather to punish magistrates and judges for their errors; there
exists no evidence that judges and magistrates are inclined to ignore the
Fourth Amendment of the Constitution and that their actions would require the
ultimate sanction of exclusion; there is no evidence that suppression of
evidence obtained under a search warrant will have any deterrent effect upon
judges and magistrates" (United States v. Leon, 2013).
To conclude, the decision of this case lessened the
exclusionary rule protections under the 4th Amendment of the Constitution which
made many law enforcement official content about the decision because of their
often felt dissatisfaction of judicial decisions that allowed a criminal to
avoid conviction because of a technical mistake by the police (United States v. Leon - 468 U.S. 897 (1984)). On the other hand, those who are committed to
4th Amendment rights, cried foul against any exceptions to the exclusionary
rule (United States v. Leon - 468 U.S. 897 (1984)).
Works Cited
United States v. Leon - 468 U.S. 897 (1984). (n.d.). Retrieved 03 23, 2013, from Justia.com US
Supreme Court Center:
http://supreme.justia.com/cases/federal/us/468/897/case.html
United States v.
Leon. (2013). Retrieved 03 23, 2013,
from Case Briefs:
http://www.casebriefs.com/blog/law/criminal-procedure/criminal-procedure-keyed-to-weinreb/the-fourth-amendment-arrest-and-search-and-seizure/united-states-v-leon-4/2/
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