Davis v. United States

131 S. Ct. 2419 (2011).

Defendant was a passenger in a car when he was arrested for giving false name to the police officers.  After Defendant was handcuffed and in the process of securing the scene, the officers searched the car and found Defendant’s gun.  Defendant was charged and convicted of being a felon in possession of a firearm.

While Defendant’s appeal was pending, the U.S. Supreme Court in Arizona v. Grant adopted a new rule governing automobile searches incident to arrests of recent occupants which made the search of the car in the instant action in violation of the Fourth Amendment.

The Court, however, affirmed Defendant’s conviction because, while the search violated the Fourth Amendment under the new precedent, the exclusionary rule did not apply to require suppression of the firearm since the officers conducted the search in objectively reasonable reliance on the then-existing and binding judicial precedent.  The Court reasoned that the sole purpose of the exclusionary rule was to deter deliberate or reckless disregard of the Fourth Amendment rights, the police acted with an objectively reasonable and good-faith belief that their conduct was lawful, and the exclusionary rule did not require deterrence of such conduct.  In addition, while the new precedent applied retroactively to the defendant during his appeal, the exclusionary rule did not automatically apply to the unconstitutional search since the purpose of the rule was not advanced by suppression of the evidence.

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