Anthony is currently a County Civil Prosecutor and has his Juris Doctorate. He has been a guest lecturer at several local universities.
Police officers from the Burbank, California Police Department were conducting a drug-trafficking investigation. During their investigation they conducted surveillance of Alberto Leon and Richardo Del Castillo. The police officers also had a confidential informant who provided them with information. Based on their independent investigation and the confidential informant's information, they prepared a search warrant application for Leon's three residences and his automobiles. Part of this application included an affidavit, a written statement confirmed by oath, often used in court proceedings.
After the application was reviewed by several district attorneys, it was presented to a state court magistrate (and officer of the State, usually referred to as a judge) and signed by Officer Rombach. The state court magistrate then issued the search warrant. During the execution of the search warrant, large quantities of drugs and other evidence of Leon's criminal conduct was found.
At the trial court, in this case the district court, Leon's defense counsel filed a motion asserting that the affidavit of the search warrant was insufficient to establish probable cause for search warrant to be issued. The trial court sided with Leon's defense counsel, and the search warrant was invalid. They also concluded that although Officer Rombach acted in good faith, there was no 'good faith exception' (the police officer's belief that he was acting according to the law) to the Fourth Amendment's exclusionary rule, as the district attorneys attempted to argue.
This case was then brought to the Court of Appeals, affirmed, and finally appealed before the United States Supreme Court.
The issued presented before the U. S. Supreme Court was whether a 'good faith exception' to the Fourth Amendment's exclusionary rule should be recognized.
The U.S. Supreme Court determined that there should be an exception to the exclusionary rule of the Fourth Amendment. They held that when a police officer acts in a reasonable manner relying on a search warrant that was issued by a neutral magistrate, but ultimately found to be invalid, the evidence collected should not be barred from trial.
The U.S. Supreme Court examined the Fourth Amendment's origin and purpose when determining whether or not to impose exclusionary rule in this particular set of facts. They weighed the benefits and the costs of preventing the District Attorney's from using the inherently trustworthy and tangible evidence in their case in chief.
After weighing those factors they determined that the exclusionary rule should be used where a Fourth Amendment violation has been substantial and deliberate, but that a balancing approach should be used in determining whether the rule should be applied in a variety of contexts, including criminal trials. This suggests that the rule should be modified to permit the introduction of evidence obtained by officers reasonably relying on a warrant issued by a detached and neutral magistrate.
They U.S. Supreme Court's rationale for the Fourth Amendment is to deter police misconduct. This was an essential part of determining whether or not the 'good faith exception' would apply in this case. Here it was the magistrate's error, not the police officer's, that caused the search warrant to become invalid. The court determined that the Fourth Amendment cannot be used to deter objectively reasonable law enforcement activity. It was their determination that an officer cannot be expected to question the magistrate's probable cause determination or his judgment; the form of the warrant is technically sufficient. Once the warrant is issued, the police officers must then comply with the laws and should not be penalized for a magistrate's error in the issuing of the warrant.
In conclusion, United States v. Leon was a landmark legal case which established an exception to the exclusionary rule of the Fourth Amendment: that evidence obtained from invalid search warrants due to a judicial, or magistrate-made, error was still admissible, provided one could demonstrate that the magistrate issuing the search warrant was neutral and detached, that there was substantial basis for determining the existence of probable cause, and that there was no police misconduct.
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Intro to Criminal Justice: Help and Review14 chapters | 548 lessons
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