Keith Mack
The exclusionary rule in the United States was established by the Supreme Court in 1914 in the case of Weeks v. United States. The rule, which is not explicitly mentioned in the Fourth Amendment, was created to deter law enforcement officers from conducting unreasonable searches and seizures and to provide remedies to defendants whose rights have been infringed. The rule was made applicable to the states in the 1961 case of Mapp v. Ohio. Since its inception, the exclusionary rule has been modified by the Supreme Court numerous times, with exceptions now outweighing its original scope.
| Characteristics | Values |
|---|---|
| Case Name | Mapp v. Ohio |
| Court Decision Date | 1961 |
| Court Decision | The exclusionary rule is an essential ingredient of the Fourth Amendment |
| Precedents | Weeks v. United States (1914), Wolf v. Colorado (1949), Elkins v. United States (1960), People v. Cahan (1955) |
| Exceptions | Good-faith exception, inevitable discovery, independent source, attenuation of evidence |
| Applicability | Applies to illegally gathered evidence used to "impeach" or attack the credibility of defendants' testimony |
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What You'll Learn
Mapp v. Ohio (1961)
Mapp argued that her Fourth Amendment rights had been violated by the search and took her appeal to the United States Supreme Court. At the time of the case, unlawfully seized evidence was banned from federal courts but not state courts. The Supreme Court ruled in a 5-3 vote in favour of Mapp, stating that evidence seized unlawfully, without a search warrant, could not be used in criminal prosecutions in state courts.
The case of Mapp v. Ohio established the exclusionary rule, which holds that evidence obtained in violation of the Fourth Amendment is inadmissible in criminal trials. This rule was first established in the 1914 decision in Weeks v. United States and was expanded upon in Mapp v. Ohio to apply to state courts. The exclusionary rule is based on the principle of deterring police misconduct and promoting judicial integrity.
The impact of Mapp v. Ohio was significant, as it ensured that the Fourth Amendment protection against unreasonable searches and seizures was fully applicable to the states. It set a precedent for future cases and modified the exclusionary rule so that its exceptions became more important than the original rule itself.
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United States v. Leon (1984)
In the United States v. Leon case of 1984, the Supreme Court established the "good faith" exception to the Fourth Amendment exclusionary rule. The case revolved around a drug-trafficking investigation conducted by officers of the Burbank, California, Police Department. Acting on a tip from a confidential informant, the police initiated surveillance of the respondents' activities and prepared an application for a search warrant. The application included an affidavit summarizing the officers' observations and was reviewed by several Deputy District Attorneys. A state court judge issued a facially valid search warrant, and the ensuing searches produced large quantities of drugs and other evidence.
The respondents were indicted for federal drug offenses and filed motions to suppress the evidence seized pursuant to the warrant. They argued that the affidavit underlying the warrant was insufficient to establish probable cause. The District Court granted the motions in part, agreeing that the affidavit did not establish probable cause. However, the Court of Appeals concluded that the information provided by the informant was inadequate, and the affidavit did not form a proper basis for the search.
Despite the issues with the warrant, the Supreme Court upheld the evidence collected during the search. The Court established that the exclusionary rule does not apply when a law enforcement officer conducts a search in objectively reasonable reliance on a search warrant issued by a detached and neutral magistrate, even if the warrant is later deemed invalid. In this case, the police officers' reliance on the state court judge's determination of probable cause was deemed objectively reasonable.
The United States v. Leon decision modified the exclusionary rule, highlighting that the rule's purpose is to deter police misconduct rather than provide a constitutional right to the accused. This case set a precedent for similar cases, such as Massachusetts v. Sheppard, where the Supreme Court upheld evidence collected during a homicide investigation despite problems with the search warrant.
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Illinois v. Krull
In 1981, an Illinois statute required licensed motor vehicle and vehicular parts sellers to allow state officials to inspect certain records. Under this statute, a police detective entered the respondents' automobile wrecking yard and asked to see the records of vehicle purchases. The respondents could not locate the records but provided a list of approximately five purchases. The detective then requested and received permission to inspect the cars in the yard. He discovered that three of the vehicles were stolen, and a fourth had its identification number removed. The detective seized the cars, and the respondents were arrested and charged with various crimes.
The state trial court granted the respondents' motion to suppress the evidence seized from the yard, agreeing with a federal court ruling that the state statute violated the Fourth Amendment by permitting officers unbridled discretion in their warrantless searches. The Appellate Court of Illinois, First Judicial District, vacated the trial court's ruling and remanded the case for further proceedings. It observed that Detective McNally's good-faith reliance on the state statute might be relevant in assessing the admissibility of the evidence.
The case, Illinois v. Krull, reached the U.S. Supreme Court in 1987. The Court held that even if the statute was unconstitutional due to vesting state officials with excessive discretion, this defect would not have been obvious to a police officer acting in good faith. The Court reversed and remanded the decision, with Justice Blackmun delivering the opinion of the Court.
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Miranda v. Arizona
The case of Miranda v. Arizona addressed four different cases involving custodial interrogations. In each case, the defendant was questioned by police officers, detectives, or a prosecuting attorney in a room where he was cut off from the outside world. None of the defendants were given a full and effective warning of their rights at the outset of the interrogation process.
In the case of Miranda, he was arrested at his home, taken into custody, and identified by the complaining witness. He was then interrogated by two police officers for two hours, which resulted in a signed, written confession. At trial, the oral and written confessions were presented to the jury. Miranda was found guilty of kidnapping and rape and was sentenced to 20-30 years imprisonment on each count.
On appeal, the Supreme Court of Arizona held that Miranda's constitutional rights were not violated in obtaining the confession. However, the U.S. Supreme Court overturned his conviction and remanded his case back to Arizona for retrial. Miranda was retried in 1967, and this time, the prosecution introduced other evidence and called witnesses. Miranda was convicted again and sentenced to 20 to 30 years in prison.
The Supreme Court's decision in Miranda v. Arizona was seen as a radical change in American criminal law, as the Fifth Amendment was traditionally understood only to protect against formal types of compulsion to confess, such as threats of contempt of court. The case made the Miranda warning part of routine police procedure to ensure that suspects were informed of their rights, which became known as "Miranda rights." The concept of "Miranda warnings" quickly caught on across American law enforcement agencies, who referred to the practice as "Mirandizing."
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Weeks v. United States (1914)
The case of Weeks v. United States arose when police officers, without a warrant or consent, searched the home of Fremont Weeks, a suspected bootlegger, and seized papers that were later used as evidence against him in a federal court. Weeks argued that the evidence obtained through the warrantless search violated his Fourth Amendment rights against unreasonable searches and seizures and was therefore inadmissible in court. The Supreme Court agreed with Weeks, holding that the Fourth Amendment applied to federal law enforcement officers and that evidence obtained unconstitutionally was inadmissible.
The Court's decision in Weeks v. United States had important implications for the protection of individual rights and the accountability of law enforcement officials. It served as a check on law enforcement, discouraging them from conducting unconstitutional searches and seizures. The exclusionary rule ensures that criminal trials are conducted fairly and justly, protecting the rights of the accused.
In the years following the Weeks decision, the US Supreme Court has modified the exclusionary rule, creating exceptions and limits. The Burger Court in the 1970s and 1980s redefined the rule's purpose as solely deterring police misconduct rather than being a constitutional right of the accused. Despite these modifications, the exclusionary rule remains a crucial aspect of the Fourth Amendment's protection against unreasonable searches and seizures.
In conclusion, Weeks v. United States (1914) is a significant case in US legal history as it established the exclusionary rule, which continues to play a vital role in safeguarding individuals' rights and ensuring fair criminal proceedings.
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Frequently asked questions
The exclusionary rule was established in the 1914 decision in Weeks v. United States.
The exclusionary rule is a court-created remedy and deterrent that applies to improperly elicited self-incriminatory statements gathered in violation of the Fifth Amendment. It also applies to evidence gained when the government violates the defendant's Sixth Amendment right to counsel.
In the United States v. Leon case, an informant told a police officer about drug sales from a residence. The circuit court of appeals upheld the suppression of the evidence due to problems with the warrants. The U.S. Supreme Court overturned this decision, holding that the exclusionary rule does not apply when a law enforcement officer conducts a search in objectively reasonable reliance on a search warrant issued by a neutral magistrate, even if it is later determined to be invalid.
Yes, there are several exceptions to the exclusionary rule. For example, the good-faith exception states that evidence is not excluded if it is obtained by officers who reasonably rely on a search warrant that later turns out to be invalid. Another exception is that the rule does not apply in civil cases, including deportation hearings.
Yes, decisions by the U.S. Supreme Court have modified the exclusionary rule significantly. Most of the limits on the rule were created or expanded by the Burger Supreme Court of the 1970s and 1980s, which redefined the rule's purpose as solely deterring police misconduct instead of being a constitutional right of the accused.
