In Which Cases the Exclusionary Rule Was Established ?
In Which Supreme Court Case the Exclusionary Rule Was Established?
"The exclusionary rule bars the prosecution from using at trial evidence that has been obtained through violation of the Fourth Amendment." (U.S. v. Shelter (9th Cir. 2011) 665 F.3d 1150, 1156.)
The purpose of the rule is to deter further Fourth Amendment violations. (Davis v. U.S. (2011) 131 S.Ct. 2419.
The courts have recognized exceptions to the exclusionary rule, for example, where the rule's application fails to yield deterrent value or when the deterrence benefits of suppression do not outweigh its heavy costs to the judicial system and to society at large. (Id. at pp. 2426-2427).
Thus, "when the police exhibit 'deliberate,' 'reckless,' or 'grossly negligent' disregard for Fourth Amendment rights, the deterrent value of exclusion is strong and tends to outweigh the resulting costs. But when the police act with an objectively 'reasonable good-faith belief' that their conduct is lawful , or when their conduct involves only simple, 'isolated' negligence, , the '"deterrence rationale loses much of its force,"' and exclusion cannot 'pay its way.'" (Davis, supra, at pp. 2427-2428.)
In Davis, the court applied the good faith exception to the exclusionary rule to a situation identical to the one here "when the police conduct a search in objectively reasonable reliance on binding judicial precedent." (Id. at p. 2428.)
"The police acted in strict compliance with binding precedent, and their behavior was not wrongful. Unless the exclusionary rule is to become a strict-liability regime, it can have no application in this case." (Id. at pp. 2428-2429.)
In Davis, the United States Supreme Court evaluated the applicability of the good faith exception in a case involving a change in the law concerning the permissibility of automobile searches incident to arrest. The Court held that "searches conducted in objectively reasonable reliance on binding appellate precedent are not subject to the exclusionary rule." (Davis, supra, 131 S.Ct. at pp. 2423-2424, 2426-2429.)
The Court explained the exclusionary rule is not a personal constitutional right nor is it designed to redress the injury caused by an unconstitutional search; rather, its sole purpose is to deter future Fourth Amendment violations. (Id. at p. 2426.)
"For exclusion to be appropriate, the deterrence benefits of suppression must outweigh its heavy costs." (Id. at p. 2427.)