Davis v. United States
131 S. Ct. 2419
| SCOTUS | 2011Background
- Fourth Amendment exclusionary rule deters future violations, not a right itself.
- Question: should exclusion apply when police act in objectively reasonable reliance on binding appellate precedent later overruled.
- Belton held vehicle searches incident to custodial arrests were allowed; subsequent Gant narrowed this rule.
- Davis conducted a vehicle search in 2007 under Gonzalez (Eleventh Circuit) precedent, later overruled by Gant (2009).
- Davis was convicted; Eleventh Circuit applied new rule but declined suppression based on lack of deterrent value.
- Court holds exclusionary rule does not apply when police rely on binding appellate precedent in good-faith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether good-faith reliance on binding precedent defeats suppression | Davis: reliance on Gonzalez warrants suppression. | Respondent: good-faith limits apply; punishment not justified. | Exclusionary rule does not apply. |
| Retroactivity vs. remedy in applying new Fourth Amendment rules | Retroactivity requires suppression where precedent overruled. | Remedy depends on deterrence; retroactivity separate from remedy. | Retroactivity governs direct relief; remedy (suppression) limited by good-faith. |
| Impact on deterrence when precedent is overruled but police act lawfully under old rule | Exclusion should deter even blameless adherence to old rule. | Deterrence would be undermined; good-faith mitigates harm. | Exclusionary rule not triggered; deterrence served by policing in good faith. |
Key Cases Cited
- Chimel v. California, 395 U.S. 752 (U.S. Supreme Court, 1969) (initial framework for searches incident to arrest)
- New York v. Belton, 453 U.S. 454 (U.S. Supreme Court, 1981) (bright-line rule for automobile searches incident to arrests)
- Arizona v. Gant, 556 U.S. 332 (U.S. Supreme Court, 2009) (overruled Belton to require additional conditions for auto searches)
- United States v. Leon, 468 U.S. 897 (U.S. Supreme Court, 1984) (good-faith exception to exclusionary rule)
- Illinois v. Krull, 480 U.S. 340 (U.S. Supreme Court, 1987) (good-faith exception for reasonable reliance on invalid statutes)
- Evans v. United States, 514 U.S. 1 (U.S. Supreme Court, 1995) (database/clerical errors and good-faith reliance)
- Herring v. United States, 555 U.S. 135 (U.S. Supreme Court, 2009) (isolated negligence and diminished deterrence value)
- Griffith v. Kentucky, 479 U.S. 314 (U.S. Supreme Court, 1987) (retroactivity for new constitutional rules applied to direct review)
- Linkletter v. Walker, 381 U.S. 618 (U.S. Supreme Court, 1965) (retroactivity factors prior to Griffith)