United States v. Leon, 468 U.S. 897 (1984)

Facts

An informant of unproven reliability tipped the Burbank Police Department that Armando and Patsy were selling drugs from their residence.  Police investigated and began to track individuals with a history of drug transactions coming and going from the residence.  The police requested a search warrant, which was issued.  The search turned up substantial quantities of cocaine and methaqualone.

Procedural History

Respondents moved to suppress the evidence.  The District Court suppressed in part, finding that the affidavit was insufficient to establish probable cause but also that none of the respondents had standing to challenge all of the searches.  The Court also found Officer Rombach acted in good faith.

Issue(s)

Does the exclusionary rule provide for an exception based on “good faith” of the officer?

Holding(s)

Yes.

Reasoning/Analysis

The Court looked at the history of exceptions created to the exclusionary rule and also found that they had yet to recognize a good-faith exception.  But the balancing approach that has evolved during the years of experience with the rule provides strong support for the modification currently urged upon us.  The marginal or nonexistent benefits produced by suppressing evidence obtained in objectively reasonable reliance on a subsequently invalidated search warrant cannot justify the substantial costs of exclusion.  As applied to the facts, Officer Rombach’s affidavit was based on extensive investigation and the officer’s reliance on the magistrate’s determination of probable cause was objectively reasonable.

Judgment/Outcome

The Court reversed the judgment of the Court of Appeals.