U.S. v. Leon Case Brief

U.S. v. Leon, 468 U.S. 897, 104 S.Ct. 3430 (1984)

FACTS: After an investigation, which included an anonymous tip, officers applied for a warrant to search three houses and the automobiles of three suspects, of which Leon was one. The warrant was issued and the searches yielded large quantities of drugs and other evidence. During a suppression hearing, the court found the warrants, while accurate on their face, were unsupported by probable cause, and as such, the evidence was suppressed. The cases were eventually dismissed for lack of evidence The prosecution argued that since the officers who executed the warrant were acting in good faith, in reliance of a warrant, that it was inappropriate to suppress the evidence.

ISSUE: Is there a “good faith” exception to the Exclusionary Rule?

HOLDING: Yes

DISCUSSION: The exclusionary rule is designed to deter police misconduct rather than to punish the errors of judges and magistrates. The deterrent purpose of the exclusionary rule necessarily assumes that the police have engaged in willful, or at the very least negligent, conduct which has deprived the defendant of some right. Evidence obtained from a search should be suppressed only if the law enforcement officer had knowledge, or should have known, that the search was unconstitutional. By refusing to admit evidence gained as a result of such conduct, the courts hope to instill a greater degree of care toward the rights of an accused.

When an officer, acting with objective good faith, has obtained a search warrant from a judge or magistrate and acted within its scope, there is no police illegality to deter. It is the magistrate's responsibility to determine whether the officer's allegations establish probable cause and, if so, to issue a warrant. In the ordinary case, an officer cannot be expected to question the magistrate's probable-cause determination or his judgment that the warrant is technically sufficient. Once the warrant is issued, there is literally nothing more the policeman can do in seeking to comply with the law. Penalizing the officer for the magistrate's error, rather than his own, cannot logically contribute to the deterrence of Fourth Amendment violations.

Because a search warrant provides the detached scrutiny of a neutral magistrate, which is a more reliable safeguard against improper searches than the hurried judgment of a law enforcement officer engaged in the often competitive enterprise of ferreting out crime, we have expressed a strong preference for warrants and declared that in a doubtful or marginal case a search under a warrant may be sustainable where without one it would fail. Reasonable minds frequently may differ on the question whether a particular affidavit establishes probable cause, and the preference for warrants is most appropriately effectuated by according great deference to a magistrate's determination.

Deference to the magistrate is not boundless. First, a magistrate's finding of probable cause does not preclude inquiry into the knowing or reckless falsity of the affidavit on which that determination was based. Second, the courts must insist that the magistrate perform his neutral and detached function and not serve merely as a rubber stamp for the police. A magistrate failing to manifest that neutrality and detachment acts as an adjunct law enforcement officer, and cannot provide valid authorization for an otherwise unconstitutional search. Third, the warrant must be based on an affidavit that provides the magistrate with a substantial basis for determining the existence of probable cause. Sufficient information must be presented to the magistrate to allow that official to determine probable cause; his action cannot be a mere ratification of the bare conclusions of others.