Illinois v. Krull, 480 U.S. 340 (1987)

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

  1. 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.
  2. 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.
  • 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.