Case Citation: United States v. Leon, 468 U.S. 897 (1984)
Parties: United States / Petitioner
Alberto Antonio Leon / Defendant
Facts
Officers of the Burbank Police Department, California, received a note from their confidential informant pointing to the need for paying special attention to activities of Armando Sanchez and Patsy Stewart because they were involved in illegal drug trafficking (cocaine and methaqualone) selling substances from their homes.
Procedural history
Police officers of one of the police departments in Burbank, California, received a note informing of illegal drug trafficking. Believing that two suspects – Armando Sanchez and Patsy Stewart – initiated a drug selling campaign at their homes, the police department officers started monitoring the activities of the suspects mentioned above. The rationale for beginning the investigation is the fact that an informant was confidential and witnessed one of the selling operations conducted by “Armando” and ”Patsy.” The informant claimed that the suspects sold methaqualone and cocaine.
The officers observed activities close to the suspects’ home and tied two more people to the illegal scheme. Based on their findings, their applied for a warrant to search houses and automobiles of the suspects as well as two respondents tied to them. As the state court judge issued a warrant, the officers detected drugs in suspects’ homes and automobiles. It is essential to note that the warrant mentioned a wide range of substances, including those mentioned by the confidential informant.
A grand jury of the Court came to the conclusion that “Armando” and “Patsy” were involved in illegal drug trafficking. Regardless of it, the case is connected to an appellation concerning the eligibility of applying for a warrant. In fact, after the case was solved and “Armando” and “Patsy” were found guilty, it was concluded that the warrant was invalid because the officers had not provided enough evidence and reasonable cause for getting a warrant.
Issue
Whether evidence collected after a warrant was issued by a neutral and detached magistrate should be used for solving the case in light of an unclear declaration of a good faith exception to the exclusionary provision mentioned in the Fourth Amendment to the U.S. Constitution?
Holding
Yes. Even though a warrant issued by a neutral and detached magistrate was found invalid, the collected evidence should not be ignored because there must be an exception to the exclusionary rule stated in the Fourth Amendment to the U.S. Constitution that allows using the obtained facts for passing a just verdict – finding “Armando” and “Patsy” guilty for establishing a network for illegal drug trafficking at their homes.
Reasoning
The Supreme Court reversed the case due to the following reasons:
- The exclusionary rule mentioned in the Fourth Amendment to the U.S. Constitution should not be applied to ignoring the collected evidence due to the potential benefits of the case outcomes.
- The Supreme Court has concluded that the exclusionary rule should be amended so that it is always viewed from the perspective of cost-benefit analysis. Because in the case of Armando Sanchez and Patsy Stewart, the decision to find them guilty is associated with monitoring the problem of illegal drug trafficking, the benefits (potential positive shifts in the local community due to the reduced access to cocaine and methaqualone) outweigh the costs (the lack of evidence for issuing the warrant and the violation of the legal procedures related to reasonable investigation). In addition, the violation of the exclusionary rule was insignificant so that it can be ignored and the obtained facts should not be barred from the investigation.
- Police officers acted in a professional and reasonable manner
- Even though the warrant was found invalid, police officers acted in accordance with the provisions stated in the issued warrant. In addition, regardless of failing to provide reasonable cause for getting a warrant, this failure may be associated with the magistrate’s inability to identify such a cause, not officers’ incompetence in providing enough evidence.
Decision
Any time when a police officer acts in accordance with a warrant issued by a neutral and detached magistrate, i.e. does not go beyond any stated provisions mentioned in it, all evidence collected during the investigation should not be ignored in solving the case. It is true even if the warrant is found invalid due to failing to provide a reasonable cause for getting it. However, this rule is applicable only to cases when benefits of adhering to this provision outweigh potential costs connected to ignoring it. Therefore, this is an exception to the exclusionary rule mentioned in the Fourth Amendment to the U.S. Constitution, and the exclusionary rule may be interpreted in a more flexible and adaptable manner.
Comment: This case is a perfect example proving that even the Constitution provisions should be perceived and interpreted objectively under different circumstances. From this perspective, it is always better to make a little exception when an insignificant violation of investigation procedures (potential cost) leads to significant benefits, especially when it comes to addressing vital social issues.