United States v. Leon: Exclusionary Rule – PLSC 337-01: The American Legal System

United States v. Leon primarily examines the costs and benefits of exclusionary clause of the Fourth Amendment as it applies to warrants. In 1981, the police received a tip from a source that is accepted as being unreliable. This tip identified Patsy Stewart and Armando Sanchez from Burbank, California as drug dealers with small quantities of drugs in their home. From this tip, the police began surveillance of their homes and discovered that a car belonging to Ricardo Del Castillo, who had a history of drug possession, was frequenting the house. From Del Castillo’s probation record, the police discovered a connection to Alberto Leon, a known drug dealer. A warrant was obtained from a magistrate based on the tip from an unreliable source, the information gathered via surveillance, and information from a detective’s affidavit. After a search, a large quantity of drugs was found and the four were arrested. The Court of Appeals found that the warrant and subsequent evidence was not permissible, but the Supreme Court ultimately found that it was.

The defense argues that the warrant is invalid due to the unreliability of the original informant as well as the assertion that the informants claims were based on information from five months earlier. The state didn’t disagree with the technical invalidity of the warrant, but instead argued that the court shouldn’t discard the warrant because the officers believed they were acting within the confines of the law and a valid warrant, i.e. “good faith.”

The legal question in this case is whether or not evidence obtained by a search warrant that is ultimately found to be invalid due to lack of probably cause must be excluded. This examines the role of the exclusionary rule under the Fourth Amendment. The court found that the exclusionary rule is not in place to correct the mistakes of law enforcement, but to safeguard a person’s Fourth Amendment rights through the deterrent effect. This means that evidence collected even after a police error can still potentially be valid, as long as a person’s Fourth Amendment rights are not validated.

The Supreme Court found that the evidence was admissible, and in doing so, undermined the authority of the exclusionary rule. Justice White wrote the majority opinion, and outlined the problems with the exclusionary rule. In overturning the Court of Appeals ruling, which applied the exclusionary rule, the Court signaled a movement away the old legal standard. The greatest problem was the potential that guilty defendants will receive lesser sentences or go free due to exclusion of evidence, even if the officers acted in good faith. To allow this would belittle the truth-finding aspect of the law, since the officers believed that they were acting within the confines of their role as police and the law. The majority still expressed a preference for a warrant and a deference to a magistrate, meaning that there still must be inquiry into the reliability of a source and that a magistrate cannot be used as a “rubber stamp” for the police. The majority believes that this ruling will not affect the strictness of the Fourth Amendment or the rights it gives people.

The dissenting opinion was written by Justice Brennan, and he explains that the majority opinion exaggerates the costs of adhering to the Fourth Amendment via the exclusionary rule, and ignores the benefits. He stresses the notion that we, as a society and judicial system, are being overwhelmed by a sense of urgency to fight crime, and in our attempts to do so, are stepping on individual rights to privacy.

I agree with the majority opinion in this case. I believe that if it can be proved that the officers were acting in good faith, then their discovery of a crime should not be excluded. With that in mind, it is necessary to prove that the officers truly were acting in good faith and are not simply using it as an method of circumventing the law. I think a similar comparison to the ruling in United States v. Leon is the concept of self-defense. If you are in a position where you believe that someone is attempting to harm you, you have the right to defend yourself. Whether or not that person ultimately was intending to harm you is less significant than if you believed it to be true. If you believe that you are in danger, you are legally able to act on that fear.

Anne Collom says:

March 21, 2017 at 10:14 pm

I agree with this analysis of United States v Leon. The overall conflict about the exclusionary principle is very interesting, and creates a unique dynamic within this case. I agree with Emily, that the evidence collected by police officers with a warrant should have been allowed to be used in court to convict Stewart, Sanchez, Del Castillo, and Leon. Therefore, we are agreeing with the overall decision of the Supreme Court. However, the manipulation of the exclusionary principle could potentially allow many issues to arise in future cases. The exclusionary principle seems to be created in order to protect the 4th amendment by deterring police from abusing their power. It intends to protect the rights of people from unreasonable search and seizure that could occur from the abuse of power of police officers. What is so interesting about this case is that the issue brought up was the question of the legitimacy of the warrant. That warrant being based on the probable cause determined by a judge or magistrate. It is due to obtaining a warrant that the police went forward to seize further incriminating evidence. Since there was no abuse of power or authority by the police in collecting evidence and since the police were acting with good faith in belief that their warrant was valid, it seems that the evidence should be used. However, what does this do to stop judges and magistrates from approving warrants with questionable probable cause in the future? And more importantly, if police officers have to worry about the validity of their warrants, how can we expect them to be able to do their job efficiently? The legal system has to be able to operate in a way that the parts can trust each other to do their job properly. The lack of trust creates inefficiency that doesn’t allow for the progress of justice. Therefore, though the exclusionary principle was altered through the decision of this case, it seems like a necessary adjustment in order to ensure the stability and trust between police officers and judges.