United States v. Leon

The Case of United States v. Leon raises an important issue with regard to the exclusionary rule: is there an exception for police officers who act in good faith.

Police received an anonymous tip from an informant identifying Patsy Stewart and Armando Sanchez as drug dealers.  The informant also provided information as to where drugs were stashed in houses around Burbank, CA.  After receiving the tip, police put one of the houses under surveillance where they identified a car belonging to Ricardo Del Castillo, a man with a history of drug possession.  Police investigated Del Castillo’s records, leading them to known drug dealer Alberto Leon.  Officer Romach presented an affidavit to a judge which was later granted, and thus led to the search of several residences where large quantities of drugs seized.  Leon, Stewart, Sanchez, and Del Castillo were all arrested.  At trial, the defendant’s attorneys disputed that the search was unconstitutional because the informant lacked reliability.  Additionally, the CI’s information was based on observations from five months before.  For this reason, the judge did not have probable cause to issue a warrant.  The prosecution agreed with this statement to an extent, but they argued that since the police acted in good faith, the evidence should be admissible in court.  

In a 6-3 majority vote, Justice White delivered the Opinion of the Court.  As Justice White states, the Court needs to weigh the risks and benefits of preventing invasions of privacy with honoring the legal system and putting forth all evidence in a court of law.  The exclusionary rule states that all evidence gathered through an invalid search and seizure is inadmissible at trial.  However, Justice White states that when police act in good faith and go through the proper steps to obtain a warrant from a neutral magistrate, the evidence gathered should be admissible.  The process of obtaining a warrant from an unbiased third party is a reliable safeguard against invalid searches and seizures.  Additionally, the exclusionary rule is designed to prevent police misconduct, not to punish judges and magistrates.  That being said, this rule serves no purpose to penalize law enforcement officials who act in good faith.  There is no evidence to support the claim that the exclusion of evidence in this case, or in any case for that matter, will have a deterrent effect on the issuing magistrate.  Judges and magistrates have no stake in the outcome of trials and for that reason, the threat of exclusion is insignificant.  In conclusion, Justice White declares that the, “…exclusionary rule should be modified to permit the introduction of evidence obtained in the reasonable good faith belief that a search of seizure was in accord with the fourth amendment” (U.S. v. Leon, 4).  On the other hand, Justice Brennan writes in his dissent that by this logic, the Court sanctions the use of illegally obtained evidence in a court of law.  He states that this decision weakens the exclusionary rule because police are given more freedom to secure warrants with little evidence.  

Unlike many of the other cases we have read in class, the “right” answer is less black and white.  As Justice White states, protecting individual liberties must be considered while upholding the legal system and respecting law enforcement officers who act in good faith.  url

For a brief overview of the case: