Illinois v. Krull

Supreme Court of the United States · 1987 · Criminal Law

Criminal LawFourth AmendmentExclusionary RuleAdministrative SearchesFourth Amendmentexclusionary rulegood faithobjectively reasonable reliance

Facts

Illinois regulated motor vehicle and automotive-parts businesses through a licensing scheme that required licensees to keep records and, in 1981, to permit officials to inspect records and examine business premises at any reasonable time to determine record accuracy. Detective McNally entered respondents' automobile wrecking yard pursuant to that statute, asked to see the license and purchase records, received permission to look at the cars in the yard, checked serial numbers, and discovered stolen vehicles and one vehicle with a removed identification number. The seized evidence led to criminal charges. State courts suppressed the evidence after concluding the statute authorizing the warrantless administrative search was unconstitutional.

Issue

Does the Fourth Amendment exclusionary rule require suppression of evidence obtained by an officer acting in objectively reasonable reliance on a statute authorizing a warrantless administrative search when the statute is later declared unconstitutional? If such an exception exists, was the officer's reliance on this Illinois statute objectively reasonable?

Rule

The exclusionary rule does not apply to evidence obtained by an officer acting in objectively reasonable reliance on a statute authorizing a warrantless administrative search, even if the statute is later declared unconstitutional. The exception does not apply if the legislature wholly abandoned its responsibility to enact constitutional laws or if the statute is so clearly unconstitutional that a reasonable officer should have known it was invalid.

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

Ohio enacts a statute allowing warrantless inspections of licensed scrap-metal recyclers during business hours to verify records the businesses must keep. In Cleveland, Officer Nina Patel inspects Riverfront Metals exactly as the statute directs and discovers stolen copper wire; six months later, the statute is held unconstitutional because it gave inspectors too much discretion over frequency and duration.

If Riverfront's owner moves to suppress the evidence in his criminal case, how should the court rule?

Explanation. The majority held that the exclusionary rule does not apply when an officer acts in objectively reasonable reliance on a statute authorizing a warrantless administrative search, even if the statute is later declared unconstitutional. Suppression is aimed at deterring police misconduct, and excluding evidence in these circumstances would not meaningfully deter an officer who merely enforced the law as written. The exception is unavailable only if the statute was so clearly unconstitutional that a reasonable officer should have known it, or if the legislature wholly abandoned its constitutional responsibility.