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United States v. Leon

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United States v. Leon, 468 U.S. 897 (1984), was a criminal procedure case heard by the United States Supreme Court dealing with search and seizure and the use of the good faith exception to the exclusionary rule.

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Contents

Summary of Case Facts

Law enforcement had Leon under surveillance suspecting he was engaged in illegal activities. On the basis of police surveillance and the information supplied by an untested informant, an affidavit was filed and search warrant issued. Inside the searched premises large quantities of illegal drugs were discovered and seized. Leon was charged with violating drug trafficking laws. At trial, the defendant, Leon, moved to suppress the evidence seized during the search by alleging that sufficient probable cause did not exist to issue the search warrant (information leading to issue was based on information from an untested informant with very little police corroboration). The trial court granted the motion and excluded evidence from the search, dismissing the government’s argument that the good faith exception to the exclusionary rule should apply. The Court of Appeals affirmed, and the government appealed to the United States Supreme Court.

Issue

Is there a good faith exception to the exclusionary rule?

Holding and Law

Yes. The court opined that evidence seized in good faith while executing an invalidly issued search warrant could be introduced at trial. The court went on to say that the exclusionary rule did not apply as a right, but merely as a remedy to help deter illegal police conduct. On balance, in this case, the benefits of the exclusionary rule were outweighed by the potential costs of suppressing the seized evidence and potentially allowing Leon to go free without punishment. Respect for the law is necessary; blanket application of exclusionary rule would not have deterred police conduct in this case where the search was executed in good faith on the basis of a warrant issued by a judge.

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