United States v. Leon Case Brief

Facts of the case

The exclusionary rule requires that evidence illegally seized must be excluded from criminal trials. Leon was the target of police surveillance based on an anonymous informant’s tip. The police applied to a judge for a search warrant of Leon’s home based on the evidence from their surveillance. A judge issued the warrant and the police recovered large quantities of illegal drugs. Leon was indicted for violating federal drug laws. A judge concluded that the affidavit for the search warrant was insufficient it did not establish the probable cause necessary to issue the warrant. Thus, the evidence obtained under the warrant could not be introduced at Leon’s trial.

Why is the case important?

A search warrant was issued to search the Respondent, Leon’s (the “respondent”) residence wherein a large quantity of illegal drugs was found. The affidavit upon which the search warrant was issued was found to be insufficient on its face. The evidence was suppressed at trial.

Question

Whether evidence obtained under a search warrant issued by a neutral and detached judge, but ultimately found to be unsupported by probable cause shall be excluded?

ANSWER

Justice Byron White (“J. White”) filed the majority opinion. No, only when a warrant is grounded upon an affidavit knowingly or recklessly false has the Supreme Court of the United States (“Supreme Court”) suppressed the evidence obtained as a result. First, the exclusionary rule is designed to deter police misconduct rather to punish magistrates and judges for their errors. Second, there exists no evidence that judges and magistrates are inclined to ignore the Fourth Amendment of the Constitution (“Constitution”) and that their actions would require the ultimate sanction of exclusion. Third, there is no evidence that suppression of evidence obtained under a search warrant will have any deterrent effect upon judges and magistrates. Judges and magistrates are not adjuncts to law enforcement officials and as such are neutral and have no stake in the outcome of criminal prosecutions. The suppression of evidence obtained pursuant to a search warrant should be ordered only on a case-by-case basis and only in those instances where exclusion would promote the purposes of the exclusionary rule. An officer acting in good faith and within the scope of a search warrant should not be subjected to Fourth Amendment constitutional violations. It is the magistrate’s or judge’s responsibility to ascertain whether the warrant is supported by sufficient information to support probable cause. However, the officer’s reliance must be objectively reasonable. Suppression remains an appropriate remedy where the magistrate was misled by information in an affidavit that the affiant knew was false or would have known was false except for his reckless disregard for the truth.

CONCLUSION

The U.S. Supreme Court reversed and held that the exclusionary rule should be modified to allow the admission of evidence seized in reasonable, good-faith reliance on a search warrant, even if the warrant was subsequently found to be defective. The Court held that suppression of evidence obtained pursuant to a warrant should be ordered only on a case-by-case basis and only in those unusual cases in which exclusion will further the purposes of the exclusionary rule that the exclusionary rule should not be applied to deter objectively reasonable law enforcement activity that the Fourth Amendment exclusionary rule does not bar the use in the prosecution’s case-in-chief of evidence obtained by officers acting in reasonable reliance on a search warrant issued by a detached and neutral magistrate but ultimately found to be unsupported by probable cause and that exclusion of the evidence in the present case on account of the magistrate’s erroneous probable-cause determination was inappropriate because the affidavit related the results of an extensive investigation and provided evidence sufficient to create disagreement among thoughtful and competent judges as to the existence of probable cause.

  • Advocates: Rex E. Lee Argued the cause for the United States Barry Tarlow Argued the cause for the respondent Leon Roger L. Cossack Argued the cause for the respondents Stewart et al
  • Petitioner: United States
  • Respondent: Alberto Leon
  • DECIDED BY:Burger Court
  • Location: Residence of Alberto Leon
Citation: 468 US 897 (1984)
Argued: Jan 17, 1984
Decided: Jul 5, 1984
United States v. Leon Case Brief