Illinois v. Krull
Citation and Court
480 U.S. 340 (1987) — Supreme Court of the United States
Facts
Illinois police conducted a warrantless search of an automobile wrecking yard pursuant to a state statute authorizing such administrative searches. The statute was later declared unconstitutional. Krull moved to suppress evidence obtained during the search.
Issue
Whether the good-faith exception to the exclusionary rule applies when officers conduct a search in reasonable reliance on a statute that is subsequently found to violate the Fourth Amendment.
Holding
The good-faith exception applies; evidence obtained by officers acting in objectively reasonable reliance on a statute is not subject to suppression even if the statute is later held unconstitutional.
Rule / Doctrine
The exclusionary rule’s purpose is to deter police misconduct. When officers act in reasonable reliance on a statute, excluding evidence would not deter legislative misconduct and serves no deterrent purpose against police. The good-faith exception (from United States v. Leon) extends to reliance on facially valid statutes.
Significance
Extended the Leon good-faith exception beyond warrants to statutory authorization, limiting the reach of the exclusionary rule where officers have an objectively reasonable basis for their conduct in existing law.