Exclusionary rule Flashcards
Wolf v. Colorado
Facts
The case of Wolf v. Colorado involved convictions in the Supreme Court of Colorado where evidence deemed inadmissible by federal standards was allowed, raising significant constitutional questions regarding the application of the Fourth Amendment’s protections against unreasonable searches and seizures to state actions.
The facts at the core of this legal challenge revolved around the admission of evidence in a state court, obtained through means that would be inadmissible in a federal court due to violation of the Fourth Amendment.
Issue
The primary issue before the Court was whether state convictions involving evidence obtained in violation of what would be considered Fourth Amendment protections in a federal context denied the convicted individuals the due process of law as required by the Fourteenth Amendment.
Holding
The Court held that the Fourteenth Amendment does not forbid the admission of evidence obtained by an unreasonable
Mapp v. Ohio
Facts
In the case of Mapp v. Ohio, the appellant, Dollree Mapp, was convicted for possessing obscene materials after an illegal search of her home by the Cleveland police. The police were initially seeking a suspect in connection with a bombing and believed that there was a large amount of policy paraphernalia in Mapp’s home. When the police demanded entry without a warrant, Mapp refused. They forcibly entered her home hours later, conducted a search without producing a valid warrant, and found the obscene materials. No search warrant was ever presented in court, and the validity of the search was highly questionable. The Supreme Court of Ohio upheld Mapp’s conviction, stating that the evidence obtained from the unlawful search was admissible.
Issue
The central legal issue in Mapp v. Ohio was whether evidence obtained from an unlawful search and seizure could be admissible in state court proceedings. Specifically, the case questioned the applicability of the Fourth Amendment’s protection against unreasonable searches and seizures to the states through the Fourteenth Amendment and whether the exclusionary rule, which prohibits the use of illegally obtained evidence in federal courts, also applies to state courts.
Holding
The United States Supreme Court reversed the judgment of the Supreme Court of Ohio, holding that all evidence obtained by searches and seizures in violation of the Constitution is, by the same authority, inadmissible in a state court. This landmark decision extended the exclusionary rule to the states, thereby requiring state and local law enforcement to adhere to the same standards as federal law enforcement in respecting constitutional protections against unreasonable searches and seizures.
Exclusionary Rule Exceptions
United States v. Leon
Facts
In August 1981, based on information from a confidential informant and an extensive investigation, the Burbank Police Department suspected Armando Sanchez, Patsy Stewart, Ricardo Del Castillo, and Alberto Leon of drug trafficking. The investigation included surveillance, checking criminal records, and observing transactions and movements related to the suspects. An experienced narcotics investigator, Officer Cyril Rombach, prepared a detailed warrant application, reviewed by several Deputy District Attorneys, for searching multiple properties and vehicles associated with the suspects. A State Superior Court Judge issued a search warrant, which led to the seizure of large quantities of drugs. The respondents were indicted but moved to suppress the evidence, arguing the warrant was unsupported by probable cause. The District Court partially agreed, finding the affidavit insufficient but acknowledged Officer Rombach acted in good faith. The Ninth Circuit Court of Appeals affirmed, holding that the affidavit failed to establish probable cause, and rejected the introduction of a good-faith exception to the Fourth Amendment exclusionary rule.
Issue
The primary issue was whether the Fourth Amendment exclusionary rule should be modified to allow evidence obtained by officers acting in reasonable reliance on a search warrant, issued by a neutral magistrate but ultimately found unsupported by probable cause, to be admissible in the prosecution’s case in chief.
Holding
The Supreme Court reversed the Court of Appeals’ decision, introducing a good-faith exception to the exclusionary rule. It held that evidence obtained by officers acting in reasonable reliance on a search warrant, later found to be defective, should not be automatically excluded from trial.
Herring v. United States
Exception to the exclusionary rule
Facts
Investigator Mark Anderson learned that Bennie Dean Herring had driven to the Coffee County Sheriff’s Department to retrieve something from his impounded truck. Upon checking for outstanding warrants against Herring, a warrant clerk in Coffee County found none and then contacted her counterpart in neighboring Dale County. The Dale County clerk reported an active arrest warrant against Herring based on their computer database. However, this information was incorrect; the warrant had been recalled five months earlier due to a negligent failure to update the sheriff’s computer records. Unaware of this mistake, Anderson arrested Herring, and a search incident to the arrest revealed methamphetamine and a firearm. Herring was subsequently indicted for illegal possession of the gun and drugs.
Issue
The central issue is whether evidence obtained from a search incident to an arrest, which was based on a mistakenly believed active arrest warrant due to a negligent bookkeeping error by police, should be excluded under the Fourth Amendment.
Holding
The Supreme Court held that evidence obtained from the search should not be excluded. The Court reasoned that exclusion is not an automatic consequence of a Fourth Amendment violation and that the exclusionary rule applies primarily to deter wrongful police conduct. In this case, the mistake was the result of isolated negligence that was attenuated from the arrest, and thus, the evidence should not be barred from consideration.
