United States v. Leon

SCOTUSCase
Litigants=United States v. Leon
ArgueDate=January 17
ArgueYear=1984
DecideDate=July 5
DecideYear=1984
FullName=United States v. Leon et al.
USVol=468
USPage=897
Citation=
Prior=Certiorari to the United States Court of Appeal for the Ninth Circuit.
Subsequent=701 F.2d 187, reversed.
Holding=Established that evidence obtained in good faith by police relying upon a search warrant that subsequently is found to be deficient may be used in a criminal trial.
SCOTUS=1981-1986
Majority=White
JoinMajority=Burger, Blackmun, Powell, Rehnquist, O'Connor
Concurrence=Blackmun
Dissent=Brennan
JoinDissent=Marshall
Dissent2=Stevens
LawsApplied=U.S. Const. amend. IV

"United States v. Leon", 468 U.S. 897 (1984)ref|citation, was a search and seizure case in which the Supreme Court of the United States created the "good faith" exception to the exclusionary rule.

Background

In 1981, police in Burbank, California received a tip identifying Patsy Stewart and Armando Sanchez as drug dealers. Police began surveillance of their homes and followed leads based on the cars that frequented the residences. The police identified Ricardo Del Castillo and Alberto Leon as also being involved in the operation. Based on this surveillance and information from a second informant, a detective wrote an affidavit and a judge issued a search warrant.

Arguments

The exclusionary rule (which forbids evidence obtained through illegal search and seizure from admittance in criminal trial) is "neither intended nor able to 'cure the invasion of the defendant's rights which he has already suffered.'" Justice Byron White states that the Court has previously defined the limits of the exclusionary rule and that there is therefore good reason to do so in this case. The exclusionary rule was designed to deter unlawful police action, not punish the errors of magistrates. There is no evidence that judges and magistrates are inclined to ignore suspects' Fourth Amendment rights. White also states that there is no evidence that the exclusion of evidence will deter magistrates from issuing unsound warrants.

White clarifies that suppression of evidence should continue in cases where the magistrate was misled by information supplied in an affidavit in "bad faith". As long as the person writing the affidavit wrote it in good faith, the decision is that of the magistrate and the exclusionary rule serves no useful function. The officers enforcing the warrant must be able to rely on the decision of the magistrate.

Arguing the case for the respondent was former Los Angeles prosecutor and now-ESPN legal analyst Roger Cossack.

ee also

*List of United States Supreme Court cases, volume 468
*"Olmstead v. United States" (1928)
*"Mapp v. Ohio" (1961)
*"Aguilar v. Texas" (1964)
*"Spinelli v. United States" (1969)
*"Harris v. New York" (1971)
*"Illinois v. Gates" (1983)

Further reading

*cite book |title=Criminal Justice Case Briefs: Significant Cases in Criminal Procedure |last=Hemmens |first=C. |authorlink= |coauthors=Worrall, J. L.; Thompson, A. |year=2004 |publisher=Roxbury Publishing |location=Los Angeles |isbn=1931719233 |pages= |url=
*cite journal |last=LaFave |first=Wayne R. |authorlink= |coauthors= |year=1996 |month= |title=Computers, Urinals, and the Fourth Amendment: Confessions of a Patron Saint |journal=Michigan Law Review |volume=94 |issue=8 |pages=2553–2589 |doi=10.2307/1289833 |url= |accessdate= |quote=

External links

*ussc|468|897|Text of the opinion from Findlaw.com
* [http://www.oyez.org/oyez/resource/case/409/ OYEZ Case Review]