Monday, May 02, 2005

 

Case Brief: United States v. Leon

Here's another case brief that should make the lives of law school students and CJ students a whole lot easier. Please do not copy this verbatim. Instead, use it as reference for writing your own case brief. Sometimes the issues of older cases are hard to grasp compared to the varied legal issues surrounding the cases we work on today, which is the only reason I post my own briefs.

Name of the Case

United States v. Leon, 468 U.S. 897 (1984)

Facts of the Case


After receiving a tip from a confidential informant, the Burbank Police Department began to monitor the activities of an Armando Sanchez and Patsy Stewart, of whom the police department were lead to believe were selling substantial quantities of cocaine and methaqualone from their home. The information was backed by the fact that the informant had observed a drug sale by "Patsy" at another residence a few months earlier.

Upon investigation, officers linked two other people, Ricardo Del Castillo, and Alberto Leon, to the sale(s) of illegal narcotics in association with Sanchez and Stewart. After viewing several other people arrive at three residences in which the suspects resided in, as well as automobiles, the Burbank Police officers applied for a search warrant, which was reviewed by several Deputy District Attorneys, and issued by a California Superior Court Judge. A grand jury indicted the defendants and charged them with conspiracy to possess and distribute cocaine and a variety of substantive counts.

Issue

Whether there was a due process violation by an unclear declaration of probable cause.

Court Decision

Reversed

Rationale for the Decision

Justice White wrote for the majority. The issue at hand is whether or not evidence that is seized and does not fall within the exact text of the search warrant can be admitted as evidence in a court of law, or whether it will fall under the exclusionary rule and be barred from evidence. The exclusionary rule states that evidence that is seized in violation of the Fourth and Fifth Amendments, and covered by the Fourteenth Amendment in connection with states rights, cannot be admitted into evidence in a court of law. Therefore, when the case was presented to the Court of Appeals to be reviewed, the Court declared the search warrant lacked probable cause and suppressed portions of the evidence. When the Government responded to the motion for appeal, citing that the Burbank Police officer who wrote the application for the warrant acted in good faith, it was denied. After review, Justice White quoted the cases US v. Chadwick, Johnson v. US, US v. Ventresca, and Aguilar v. Texas, in relation to a search warrant, in which the warrant itself "provides the detached scrutiny of a neutral magistrate, which is a more reliable safeguard [468 U.S. 897, 914] against improper searches than the hurried judgment of a law enforcement officer `engaged in the often competitive enterprise of ferreting out crime,'" United States v. Chadwick, 433 U.S. 1, 9 (1977) (quoting Johnson v. United States, 333 U.S. 10, 14 (1948)), we have expressed a strong preference for warrants and declared that "in a doubtful or marginal case a search under a warrant may be sustainable where without one it would fall." By this declaration, even when the warrant itself does not contain specific facts, or lacks the facts in whole, the prior investigation and statement of likely facts would entail enough probable cause the initiate the search warrant and seize applicable evidence.

Concurring Opinions

Justice Blackmun wrote the concurring opinion. Evidence obtained in good faith by peace officers does not need to be excluded in court of law, so long as the officers act in "reasonable reliance" of what is stated in the search warrant.

Dissenting Opinions

Justice Brennan wrote the dissenting opinion, and Justice Marshall joins. The exclusionary rule is demanded by the Constitution in the Fourth and Fifth Amendments, and applied to the states in the Fourteenth Amendment. By allowing the evidence to be admitted, it charges the court with a violation of due process rights, and examples such as the lack of cause shown by the search warrant should serve as a lesson to future cases, and should make officers do a more thorough job of establishing a case for the search warrant. This decision takes away the need for officers to specify exactly what they are looking for, and dictates the need to only outline, in vague terms, the conditions of the search warrant.

Holding of the Court

A search warrant lacking the proper declaration of probable cause can be initiated, and the evidence seized can be admitted into a court of law.

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