United States v. Leon

United States v. Leon is a case about the Fourth Amendment’s exclusionary rule and if it should be applied to cases in which a warrant given by a judge turns out to be without substantiation for probable cause.  This case began with two men, Pasty Stewart and Armando Sanchez, who were suspects of drug dealing.   The suspects were identified by someone without proof of reliability and the police began surveillance.  This surveillance led them to another suspect, known to have a criminal history with drugs, Ricardo Del Castillo.  The police through investigation of Castillo’s records, were led to discover a known drug dealer, Alberto Leon.  Knowledge from a second informant was then surfaced.  All this information led to an affidavit constructed by Officer Cyril Rombach, which resulted in a warrant being given.  With this warrant, police searched the alleged identified houses and places of drug activity and found a large amount of drugs.  The four suspects were then arrested.

The defense argued that the evidence be given the exclusionary rule because the lack of reliability of the first informant and their outdated information gave a lack of probable cause for a warrant to be issued.  The government argued the police officer’s actions were in “good faith” and therefore the evidence should not be discarded.

Justice White writes the majority opinion in a 6-3 vote breakdown.  White concluded that the evidence did not fall into the exclusionary rule because of many reasons including cost/benefit analysis and the absence of deterrence.  The most prominent reason though was that the officer was reasonable in believing that the judge properly issued the warrant and he acted on that warrant “in good faith.”  I believe that the court’s decision was correct.  Officer Rombach brought what he thought gave probable cause for a warrant and was granted it.  An officer should not have to question a judge’s actions because a judge’s job is separate from theirs.  Officers are simply relying on the information relayed, it is not their job to analyze the judge’s actions also.  Although, I also found the dissenting opinion written by Justice Brennan thought-provoking.  When reading the Fourth Amendment and exclusionary rule how they were written, they state that people will be protected from the usage of evidence received from unreasonable searches and seizures.  The search is technically, when going strictly by the text, unconstitutional because there was no probable cause to lead to a warrant.   The warrant would not be valid and then a lack of probably cause would protect Leon from the search.  This would be a strict constructionist reading of it.  Although the majority of Justices expanded the interpretations of the text to allow for their ruling and were loose constructionists, which I agree was necessary in this case.

In the majority opinion a lot of the reasons that led the Justices to their decisions were circumstantial to this case specifically.  I believe that since the majority of Justices did not set a very clear bar on what falls into the exclusionary rule this will result in them getting many more cases about the same topic.  One immediate question that comes to mind is what exactly constitutes “good faith.”  The steps to achieving it were laid out but also similarly vague and up to interpretation.  A definite implication of this case is that many similar cases regarding the exclusionary rule will arise.