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Davis v. United States

Supreme Court of the United States · 2011 · Criminal Procedure

Criminal ProcedureFourth AmendmentExclusionary RuleFourth Amendmentexclusionary rulegood-faith exceptionbinding appellate precedentretroactivity

Facts

In 2007, Greenville, Alabama police stopped a car and arrested the driver for driving while intoxicated and passenger Willie Davis for giving a false name. Officers handcuffed both arrestees, placed them in separate patrol cars, and then searched the passenger compartment of the vehicle, finding a revolver in Davis's jacket pocket. Davis was charged with possession of a firearm by a convicted felon. At the time of the search, the officers' conduct fully complied with binding Eleventh Circuit precedent interpreting Belton to authorize such vehicle searches incident to arrest.

Issue

Whether the exclusionary rule requires suppression of evidence when police conduct a search in objectively reasonable reliance on binding appellate precedent that is later overruled, making the search unconstitutional under a subsequently announced Fourth Amendment rule.

Rule

Searches conducted in objectively reasonable reliance on binding appellate precedent are not subject to the exclusionary rule. The exclusionary rule applies only where its deterrence benefits outweigh its substantial social costs, and suppression is unwarranted when police act without deliberate, reckless, grossly negligent, or systemic culpable misconduct.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, officers arrested Nolan Price after a traffic stop and searched the passenger compartment of his car. At the time, the Ohio Supreme Court had squarely held that such a search was permissible in these circumstances, but while Nolan's appeal was pending, a later Supreme Court decision made clear the search violated the Fourth Amendment.

If Nolan moves to suppress the drugs found in the car, what is the strongest argument against suppression?

Explanation. The majority held that evidence obtained during a search conducted in objectively reasonable reliance on binding appellate precedent is not subject to the exclusionary rule. Even if the later decision applies retroactively and establishes a Fourth Amendment violation, remedy is a separate question. Because the officers followed binding law and were not culpable, suppression would not yield meaningful deterrence and would impose substantial social costs.