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United States v. Leon

Supreme Court of the United States · 1984 · Criminal Procedure

Criminal ProcedureFourth Amendmentexclusionary rulegood faith exceptionsearch warrantFourth Amendmentexclusionary rulegood faith

Facts

Police officers obtained and executed a search warrant from a magistrate. The warrant was later challenged as unsupported by probable cause. The Court considered whether the exclusionary rule should apply when officers acted in objectively reasonable reliance on the magistrate's issuance of the warrant.

Issue

Whether the Fourth Amendment exclusionary rule requires suppression of evidence obtained by officers acting in objectively reasonable reliance on a search warrant issued by a neutral magistrate, even if the warrant is later found unsupported by probable cause.

Rule

The exclusionary rule does not bar the use of evidence obtained by officers acting in objectively reasonable reliance on a search warrant issued by a detached and neutral magistrate that is later found to be invalid. Suppression remains appropriate when reliance on the warrant is not objectively reasonable, including when the magistrate was misled by knowingly or recklessly false information, when the magistrate wholly abandoned the judicial role, when the affidavit is so lacking in indicia of probable cause as to render belief in its existence entirely unreasonable, or when the warrant is so facially deficient that executing officers cannot reasonably presume it valid.

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

In Phoenix, Detective Mara Quinn submitted a detailed affidavit to a neutral state judge seeking a warrant to search Devin Cole's apartment for stolen camera equipment. The judge issued the warrant, officers executed it, and a reviewing court later held that the affidavit did not establish probable cause because the links between the apartment and the theft were too weak.

If Devin moves to suppress the camera equipment, what is the strongest argument for admitting it?

Explanation. The majority recognized a good-faith exception to the exclusionary rule. Evidence need not be suppressed when officers act in objectively reasonable reliance on a warrant issued by a neutral and detached magistrate, even if the warrant is later found unsupported by probable cause. The rule is about the suppression remedy, not an automatic conclusion that the warrant was valid, and the standard is objective rather than merely subjective.