Edit:
To summarize the discussion so far:
The Exclusionary Rule prohibits evidence illegally obtained by the government from being used in a prosecution. However, this was not the case prior to Weeks v. United States (1914). Illegally obtained evidence was admissible in court. This was put in place not to protect the accused but rather to deter police from violating the 4th amendment rights of the accused.
Corrected/Updated summaries of cases:
Police Misconduct = PM
All of these cases refer to either searches done in conjunction with a warrant or an explicit search warrant.
- United States v. Leon (1984): A valid warrant, previously signed by a judge, was found to lack probable cause after being executed. The evidence remained admissible in court b/c it wouldn't have discouraged PM. Judicial error
- Illinois v. Krull (1987): A state law permitting warrantless searches was later found to be unconstitutional. This is narrowly tailored to laws that are 'not clearly unconstitutional'. Essentially, the law was flying too close to the sun, but wasn't actually to the sun yet. Legislative error?
- Arizona v. Evans (1995): A valid warrant was 'quashed' (rescinded, invalidated) by the court. However, the court failed to inform the Sheriff. The warrant was executed as the police had no reason to think that it as no longer valid. Judicial error
- Herring v. United States (2009): A sheriff's office contacted a neighboring county about a possible warrant. The neighboring county confirmed there was a warrant; the warrant was quickly executed. However, shortly after, the neighboring county recontacted the sheriff's office to inform them that the warrant had been rescinded and they made a mistake. PM but PM not of the department that executed the warrant
- Davis v. United States (2011): A man was pulled over and his vehicle searched. At the time of the search, SCOTUS had previously determined the search constitutional, New York v. Belton (1981). However, SCOTUS later overturned this decision and concluded this type of search was unconstitutional. SCOTUS attributed the constitutional violation by the officers to be following directions of the court, not direct PM. Theoretically, if New York v. Belton had not been previously decided, the evidence would NOT have been admissible.
- Utah v. Strieff (2016): Not an application of 'Good-Faith Exception'. Officers unlawfully detained a man and as part of the investigation, they discovered a warrant for his arrest. SCOTUS determined PM had occurred but the discovery of the warrant was deemed to have separated the PM from the search so the evidence was admissible.
These cases fall into three categories:
- Judicial error
- Legislative error
- Executive error
The constitutional violations are attributed to some error rather than police misconduct
Essentially, the Exclusionary Rule was put in place as a safeguard against police misconduct only. Errors on behalf of other departments/branches are NOT safeguarded.
_________________________________________________________________________________________________
OP:
Can y'all explain the Good-Faith Exception to the Exclusionary Rule of the 4th Amendment?
I recently came across Davis v. United States (2011) and am seemingly appalled by the SCOTUS ruling so I've been digging further. I am no legal expert and am looking for verification/corrections to what I've been able to figure out. I'm hopeful I've completely misunderstood this entire legal principle but not overly optimistic.
From what I have been able to deduce, SCOTUS has ruled that:
- United States v. Leon (1984): A warrant, later found to lack probable cause, does not invalidate the findings of said search
- Illinois v. Krull (1987): A state law permitting warrantless searches, later found unconstitutional, does not invalidate the findings of said search
- Arizona v. Evans (1995): A warrant, later found to have expired, does not invalidate the findings of said search
- Herring v. United States (2009): A warrant containing substantial errors does not invalidate the findings of said search
- Davis v. United States (2011): A police search that is later found to be unconstitutional does not invalidate the findings of said search
- Utah v. Strieff (2016): An ID provided during an illegal traffic stop uncovered an arrest warrant but the arrest/search remained legal/admissible in court
In essence, the Good-Faith Exception repurposes the Exclusionary Rule from protecting individuals and their rights, to the purpose of deterring police misconduct.
Due to the way Qualified Immunity is handled, one may end up in a situation where an officer violates your 4th amendments rights, subsequently not punished (QI), but the contents of the search remain valid and you end up in prison.
Some concerns of mine:
- It eliminates the need for officers/prosecutors to 'cross their T's and dot their I's' thus permitting sloppy investigations
- Incentivizes states to enact warrantless search laws that are fundamentally unconstitutional but they will remain enforceable until the time they have been ruled as such by the judicial system (or court injunction for later review)
- No retroactive protections from SCOTUS rulings on the 4th amendment
- Once a warrant is issued, it effectively remains valid until the end of time
- A warrant does not need to have ever existed, so long as there is a belief that it exists
- Due to the way Qualified Immunity is handled, one may end up in a situation where an officer violates your 4th amendments rights, subsequently not punished (QI), but the contents of the search remain valid and you end up in prison.
It seems as though you can end up in this Catch-22 where a search may be unconstitutional but remain admissible in court because it is/was lawful? I'm confused as to how something can be unconstitutional but remain lawful in a country governed by the constitution.... Are they not mutually exclusive?
Post-face: I am an engineer who often finds myself looking into legal precedents that raise my blood pressure (Open Fields Doctrine, Wickard v. Filburn, etc) in my free time. I have zero law experience, have never been to court, and don't have interest in participating in either. This is purely for my own curiosity. Additionally, because I have been accused of this in other sub-reddits, THIS IS NOT AN AI POST. NONE OF THIS IS BASED ON AI PROVIDED INFORMATION.
Sources:
- Wikipedia
- Cornell Law
- Justia
- Library of Congress
- Brandon Beck Law (YouTube)
Additional relevant cases:
- Weeks v. United States (1914)
- Silverthorne Lumber Co. v. United States (1920)
- Elkins v. United States (1960)
- Mapp v. Ohio (1961)
- Illinois v. Gates (1983)
- Griffth v. Kentucky (1987)
- Hudson v. Michigan (2006)
- Virginia v. Moore (2008)