holding that the exclusionary rule should not be applied to bar the use of evidence obtained by officers acting in reasonable reliance on a search warrant issued by a detached and neutral magistrate but ultimately found to be invalid, and stating that whether to apply the rule is “resolved by weighing the costs and benefits of preventing the use in the prosecution’s case-in-chief of inherently trustworthy tangible evidence obtained in reliance on a search warrant issued by a detached and neutral magistrate that is ultimately found to be defective”
How later courts described this case
- holding that the exclusionary rule should not be applied to bar the use of evidence obtained by officers acting in reasonable reliance on a search warrant issued by a detached and neutral magistrate but ultimately found to be invalid, and stating that whether to apply the rule is “resolved by weighing the costs and benefits of preventing the use in the prosecution’s case-in-chief of inherently trustworthy tangible evidence obtained in reliance on a search warrant issued by a detached and neutral magistrate that is ultimately found to be defective”
- holding that the magistrate may believe that evidence of a crime will be exclusionary rule should not be used to suppress evidence found.” Allen, 211 F.3d at 975 . However, here, as noted by when the officers who obtained the evidence acted in the federal magistrate judge in his report and reasonable reliance on a search warrant issued by a neutral recommendation, officer Engle did not provide any detail as and detached magistrate that is later found to be invalid
- explaining that, because the “purpose of the exclusionary rule is to deter unlawful police conduct,” excluding evidence obtained pursuant to a warrant will not further the ends of the exclusionary rule in situations where the offer’s conduct was objectively reasonable — situations where the law enforcement officer had no knowledge that the search was unconstitutional under the Fourth Amendment (citations omitted)
- stating exclusion could still be warranted if: (1) the warrant was based on an affidavit “so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable;” or (2) the warrant was “so facially deficient—i.e., in failing to particularize the place to be searched or the things to be seized—that the executing officers [could not have] reasonably presume[d] it to be valid”
Written by the judges who cited it.
Later courts went against this
Criticized by State v. Marsala, 216 Conn. 150 (1990)
The Leon court’s conclusion regarding the costs of the exclusionary rule has been criticized on numerous levels.
Criticized by State v. Eason, 245 Wis. 2d 206 (2001)
A fourth weakness in the majority opinion is the majority's reliance on the Leon Court's cost-benefit analysis.[33] This cost-benefit analysis for Fourth Amendment violations has been roundly criticized by courts and commentators.[34] Even if a cost-benefit analysis were an appropriate basis for implementing the good faith exception, how does the court purport to quantify the cost of constitutional protections?[35] A…
Declined to follow by Tim v. State, 14 Fla. L. Weekly 2834 (1989)
We reject the state’s argument that the “good faith” exception to the warrant requirement enunciated in United States v. Leon, 468 U.S. 897, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984), should apply.
Declined to follow by People v. Bigelow, 66 N.Y.2d 417 (1985)
The evidence in the record does not support a finding of probable cause for the arrest or the search when measured by either the AguilarSpinelli rule or the Gates rule and exclusion cannot be avoided because, as a matter of State constitutional law, we decline to apply the Leon good-faith standard.
Disagreed with by State v. Guzman, 122 Idaho 981 (1992)
Additionally, we disagree with the basic premise of the Leon decision — that the decision whether to apply the exclusionary rule should be made by determining whether the goal of police deterrence would be furthered in the case at bar— because it totally fails to take into account the other purposes of our independent state exclusionary rule.
Disagreed with by Commonwealth v. Edmunds, 526 Pa. 374 (1991)
Indeed, we disagree with that Court’s suggestion in Leon that we in Pennsylvania have been employing the exclusionary rule all these years to deter police corruption.
Distinguished
Distinguished by United States v. Steven Horton, 863 F.3d 1041 (2017)
In analyzing this good-faith exception in the context of the NIT warrant, the district court determined “that Leon is inapplicable to issuance of the NIT Warrant because the NIT Warrant was issued without jurisdiction and was, therefore, void ab initio.
Distinguished by United States v. Herron, 2 F. Supp. 3d 391 (2014)
Under Leon, the good faith exception is inapplicable and “[suppression ... remains an appropriate remedy if the magistrate or judge in issuing a warrant was misled by information in an affidavit that the affiant knew was false or would have known was false except for his reckless disregard of the truth.
Distinguished by United States v. Powers, 1 F. Supp. 3d 470 (2014)
Because it was not objectively reasonable for the executing officer to rely on the warrant, the Leon good-faith exception is inapplicable.
Distinguished by United States v. Harvey, 901 F. Supp. 2d 681 (2012)
Officer Helms then obtained a search warrant on the basis of the observations Officer Ammons made during the unlawful entry.8 As such, the Leon good-faith exception is inapplicable.
The opinion
*927 Justice Blackmun,
concurring.
The Court today holds that evidence obtained in violation of the Fourth Amendment by officers acting in objectively reasonable reliance on a search warrant issued by a neutral and detached magistrate need not be excluded, as a matter of federal law, from the case in chief of federal and state criminal prosecutions. In so doing, the Court writes another chapter in the volume of Fourth Amendment law opened by Weeks v. United States, 232 U. S. 383 (1914). I join the Court’s opinion in this case and the one in Massachusetts v. Sheppard, post, p. 981, because I believe that the rule announced today advances the legitimate interests of the criminal justice system without sacrificing the individual rights protected by the Fourth Amendment. I write separately, however, to underscore what I regard as the unavoidably provisional nature of today’s decisions.
As the Court’s opinion in this case makes clear, the Court has narrowed the scope of the exclusionary rule because of an empirical judgment that the rule has little appreciable effect in cases where officers act in objectively reasonable reliance on search warrants. See ante, at 918-921. Because I share the view that the exclusionary rule is not a constitutionally compelled corollary of the Fourth Amendment itself, see ante, at 905-906, I see no way to avoid making an empirical judgment of this sort, and I am satisfied that the Court has made the correct one on the information before it. Like all courts, we face institutional limitations on our ability to gather information about “legislative facts,” and the exclusionary rule itself has exacerbated the shortage of hard data concerning the behavior of police officers in the absence of such a rule. See United States v. Janis, 428 U. S. 433, 448-453 (1976). Nonetheless, we cannot escape the responsibility to decide the question before us, however imperfect our information may be, and I am prepared to join the Court on the information now at hand.
*928 What must be stressed, however, is that any empirical judgment about the effect of the exclusionary rule in a particular class of cases necessarily is a provisional one. By their very nature, the assumptions on which we proceed today cannot be cast in stone. To the contrary, they now will be tested in the real world of state and federal law enforcement, and this Court will attend to the results. If it should emerge from experience that, contrary to our expectations, the good-faith exception to the exclusionary rule results in a material change in police compliance with the Fourth Amendment, we shall have to reconsider what we have undertaken here. The logic of a decision that rests on untested predictions about police conduct demands no less.
If a single principle may be drawn from this Court’s exclusionary rule decisions, from Weeks through Mapp v. Ohio, 367 U. S. 643 (1961), to the decisions handed down today, it is that the scope of the exclusionary rule is subject to change in light of changing judicial understanding about the effects of the rule outside the confines of the courtroom. It is incumbent on the Nation’s law enforcement officers, who must continue to observe the Fourth Amendment in the wake of today’s decisions, to recognize the double-edged nature of that principle.