United States v. Leon
Citation: 468 U.S. 897 (1984)
Facts
Police in Burbank, California obtained a facially valid search warrant based on information from a confidential informant and their own surveillance. The warrant was later found to have been issued without probable cause. Officers who had relied on the warrant in good faith had seized drugs and other evidence. The district court suppressed the evidence under Mapp.
Issue
Whether the exclusionary rule bars the use of evidence obtained by officers who reasonably and in good faith relied on a search warrant later found to be unsupported by probable cause.
Holding
The Supreme Court held that evidence seized in objectively reasonable reliance on a subsequently invalidated search warrant need not be suppressed. The good faith exception applies when officers act with objective good faith in relying on a facially valid warrant.
Rule
Evidence obtained through a warrant that officers reasonably and in good faith believed to be valid is admissible even if the warrant is later found defective, unless: (1) the magistrate was misled by false information; (2) the magistrate wholly abandoned the judicial role; (3) the warrant was so lacking in probable cause that reliance on it was unreasonable; or (4) the warrant was so facially deficient that no officer could reasonably rely on it.
Significance
Leon is the controlling case on the good faith exception to the exclusionary rule and significantly limits Mapp’s reach. Its cost-benefit analysis of the exclusionary rule — deterrence versus social cost — has shaped all subsequent debate about when suppression is warranted. It is paired with Mapp, Herring v. United States, and Davis v. United States in studying the scope of the exclusionary rule.