Exclusionary Rule: Case Study

I find that the evidence would still be valid based on the “good faith” exception to the exclusionary rule. The good faith exception states “that If officers had a reasonable, good-faith belief that they were acting per legal authority, such as by relying on a search warrant that is later found to have been legally defective, the illegally seized evidence is admissible” (Busby, 2009). The good faith exception was established by a 6-3 U.S Supreme court decision in the United States v. Leon 468 U.S. 897 (1984). The majority opinion, as written by Bryon R. White, was that the exclusionary rule was established to deter law enforcements violations of the 4th amendment warranting against illegal search and seizure. Therefore “reliable physical evidence seized by officers reasonably relying on a warrant issued by a detached and neutral magistrate” did not violate the exclusionary rule and the evidence was to be admitted (Kaye, 2011). The good faith exception was reviewed and expanded in Arizona v. Evans 514 U.S. 1 (1995), a case that I feel directly correlates to my decision reference the admissibility of the evidence in the example given. In Arizona v. Evans an officer conducts a legal traffic stop. Upon running the driver’s license the officer discovers an outstanding warrant for arrest. Pursuant to the arrest a search was conduct and marijuana discovered. When charging Evan’s when possession the officers discovered that the warrant had been quashed. In a 7-2 decision, the U.S. Supreme Court determined that this was not a violation of Evan’s 4th Amendment rights since the evidence, though obtained based on an illegal warrant, was legal based on the good faith
exception namely the officer’s belief in the falsely reported warrant. Lastly, a more recent Supreme Court decision Herring v. United States 129 S. Ct. 695 (2009), also had a bearing on my decision. In a 5-4 decision the Supreme Court ruled that a search based on clerical error was not a violation of Herring’s 4th Amendment rights, provided that the error was a result of “isolated negligence and not systematic error or reckless disregard of constitutional requirements” (Herring v. United States, (n.d.)). Therefore, the evidence in Herring’s trial was legal despite the illegal search based on the erroneous warrant. Based on these court cases U.S.
v. Leon, Arizona v. Evans, and Herring v U.S. I feel that the precedence has been established. Even though the precipitating warrant was recalled, the evidence found pursuant to the arrest based on the officer’s good faith in the warrant is valid and can be
admitted.