United States v. Leon, 468 U.S. 897 (1984).

Brian Rice

CASE CITATION: United States v. Leon, 468 U.S. 897 (1984).

PARTIES: United States, Plaintiff / Appellant

Alberto Leon, Ricardo Del Castillo, Armando Sanchez, Patsy Stewart, Defendants / Apellees

FACTS: In August 1981, a confidential informant of unproven reliability informed Police that respondents Leon and Stewart were selling large quantities of cocaine and methaqualone from a residence at 620 Price Drive in Burbank, Cal. The informant told police that he observed both small quantities of drugs and a shoebox containing a large amount of cash at the residence. He also told police that larger quantities of the drugs were being stored at another location in Burbank. Because of this information, police began surveillance of the respondent’s residences at 620 Prince Drive, 716 South Sunset Canyon in Burbank and 7902 Via Magdalena. Police state they observed material activity at the residences and relevant activity involving the respondent’s vehicles.

Officer Cyril Rombach of the Burbank Police Department relied on both surveillance and other observations as the basis for applying for a search warrant to search the three residences and vehicles registered to the respondents for an extensive list of items believed to be related to the respondent’s drug trafficking activities. The search warrant application was reviewed by several Deputy District Attorneys and a facially valid search warrant was issued in September 1981 by a State Superior Court Judge.

The executed search yielded large amounts of drugs and other evidence at the Via Magdalena and Sunset Canyon addresses and a small quantity at the Price Drive residence. Evidence was also recovered from Stewart’s and Del Castillo’s automobiles. The Respondents were indicted and charged with conspiracy to possess and distribute cocaine and a variety of substantive counts. Motions to suppress the seized evidence were filed. 

PROCEDURAL HISTORY: The trial court ruled in favor of the motion to exclude. The Court of Appeals affirmed. The government appealed to the United States Supreme Court. Certiorari was granted.

ISSUE: Whether an exception under the Fourth Amendment exclusionary rule can be applied which would make evidence obtained admissible when police use a reasonable, good-faith reliance on the validity of the warrant, but after the search, it is held that the warrant is defective? 

HOLDING: Yes, because the intent of the exclusionary rule is to deter illegal police conduct during the execution of a search, a reasonable reliance on the validity of a search warrant does not manifest the illegal conduct the exclusionary rule was meant to deter. 

REASONING: The Court opined that the Fourth Amendment does not contain any language which expressly precludes the admission of evidence obtained in violation of Fourth Amendment provisions. The Court cited Calandra in stating that “the use of the fruits of past unlawful searches and seizures does not manifest a new violation of the Fourth Amendment (United States v. Calandra, 414 U. S. 338, 354 (1974)).” Because of Calandra, the door was opened for the Court to rule whether or not an exception could be made to the exclusionary rule without the exception manifesting itself as a new violation of the Fourth Amendment. Remembering that the question for the Court was not one of whether the defective warrant should render the seized evidence as inadmissible, but whether looking at the totality of the circumstances, whether the door to the Fourth Amendment could be thrust open to allow an exemption which could render poisonous and inadmissible fruit under a defective warrant scenario to become admissible under circumstances where the police were not a party to any wrong doing. Thus, invoking the exclusionary rule would be a misused remedy since he police reasonably acted in good-faith to execute a facially valid search warrant.

DECISION: Reversed. The Court concluded that the exclusionary rule could be modified to allow exceptions without infringing on the intended purpose of the rule.COMMENTS: In dissent, Justice Brennan and Justice Marshall argue in summary that poisonous fruit is poisonous fruit. In considering the defendant’s right to equal justice under the law, one could argue that the majority’s justification that the “costs of adhering to the exclusionary rule in cases like this exceeds the benefits,” does in itself intrude upon the very nature of the intent of the exclusionary rule which is to provide relief from State actors, when the actions of these actors casts a cloud of doubt over the legality and fairness in the practices used to collect seized evidence. Should it matter whether the respondent is harmed by intentional, illegal acts by State actors, or whether the harm is a result of some omission or failure on the part of the State? Poisonous fruit is poisonous fruit. It should not matter, whether it comes from those authorizing the search or from those performing the search.