Facts
- Illinois law required licensed motor-vehicle and vehicle-parts dealers to permit warrantless inspections of specified records and related vehicles.
- In 1981, a police detective entered an automobile wrecking yard operated by licensed dealers and requested vehicle-purchase records.
- The operators stated the records could not be found but provided a short list of recent purchases.
- With permission to inspect vehicles in the yard, the detective discovered three stolen vehicles and a fourth with a removed identification number.
- The detective seized the vehicles, and the operators were arrested and charged under Illinois motor-vehicle laws.
- The day after the search, a federal court held the inspection statute unconstitutional under the Fourth Amendment because it permitted excessive officer discretion in warrantless inspections.
Issues
- Whether the Fourth Amendment exclusionary rule requires suppression of evidence obtained during a warrantless administrative search conducted in objectively reasonable reliance on a statute later declared unconstitutional.
- Whether extending the good-faith exception to reliance on statutes is consistent with the exclusionary rule’s deterrence rationale and its costs.
Decision
- The U.S. Supreme Court reversed the Illinois Supreme Court and remanded.
- The Court held that the exclusionary rule does not apply to evidence obtained by officers acting in objectively reasonable reliance on a statute authorizing warrantless administrative searches, even if the statute is later found unconstitutional.
- The Court reasoned that excluding evidence in these circumstances would not meaningfully deter police misconduct because the officer enforced a presumptively valid law.
- The Court rejected suppression as a tool to deter legislatures, concluding the exclusionary rule principally targets police conduct and that judicial invalidation is the primary check on unconstitutional statutes.
- The Court indicated a limit: reliance is not objectively reasonable where the statute is clearly unconstitutional on its face.
Legal Principles
- The exclusionary rule is a judicial remedy primarily aimed at deterring unlawful police conduct, not a personal constitutional right.
- Evidence obtained in objectively reasonable reliance on a statute authorizing a search is not subject to exclusion solely because the statute is later held unconstitutional.
- The reasonableness inquiry is objective; officers generally may rely on legislative authorization unless the statute is clearly unconstitutional.
- Suppression requires weighing marginal deterrence against the social costs of excluding reliable evidence.
- Deterrence of legislative enactments is not a principal justification for exclusion; courts’ power to invalidate statutes is the main constraint on unconstitutional laws.
Conclusion
The Court held that the good-faith exception permits admission of evidence obtained during a warrantless administrative search conducted in objectively reasonable reliance on a statute later declared unconstitutional, because suppression would yield minimal deterrence and substantial costs, except where the statute is clearly unconstitutional.