Sunday, November 3, 2013

United States v. Leon case brief

United States v. Leon case brief summary
468 U.S. 897 (1984)

CASE SYNOPSIS
Petitioner United States appealed the decision of the United States Court of Appeals for the Ninth Circuit holding that there was no good faith exception to the U.S. Constitutional Amendment IVexclusionary rule.

CASE FACTS
This case presented the question whether the exclusionary rule should be modified so as to allow the use 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. During trial, respondents filed motions to suppress evidence seized pursuant to a warrant and said motions were granted in part based on the outcome that the warrant was not supported by probable cause despite the fact that the police officer was acting in good faith reliance on what he believed to be a valid warrant. The lower court affirmed and held that there was no good faith exception to the exclusionary rule.

DISCUSSION
  • The U.S. Supreme Court reversed and held that the exclusionary rule should be modified so as not to bar the admission of evidence seized in reasonable, good-faith reliance on a search warrant that was subsequently held to be defective. 
  • The Court concluded that the marginal or nonexistent benefits produced by suppressing evidence obtained in objectively reasonable reliance on a subsequently invalidated search warrant could not justify the substantial costs of exclusion.

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.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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