Davis v. United States, 564 U.S. 229

Davis was convicted of firearm possession; officers searched Owens’ vehicle after an April 2007 traffic stop where both occupants were arrested and handcuffed.
The Eleventh Circuit applied pre-Gant Belton-era precedent, holding a vehicle search incident to a recent occupant’s arrest was valid.
Davis challenged the search as unconstitutional under the then-binding Eleventh Circuit precedent, seeking suppression on appeal.
The Supreme Court later announced Arizona v. Gant, eliminating the pre-Gant rule and approving suppression in similar circumstances.
The question presented is whether the exclusionary rule should apply when police rely in good faith on binding appellate precedent that is later overruled.
The Court held that evidence obtained in searches conducted in objectively reasonable reliance on binding appellate precedent is not subject to suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether good-faith reliance on binding precedent defeats suppression	Davis argues exclusion deters, but the good-faith reliance should shield officers.	The government contends good-faith reliance on binding precedent warrants no suppression.	Yes; good-faith reliance bars suppression.
Retroactivity versus remedy under new Fourth Amendment rules	Overruled precedent should create suppression to deter violations.	Retroactivity concerns do not mandate suppression when reliance was reasonable.	Remedy limited; good-faith exception applies without retroactive suppression.
Effect of reliance on binding appellate precedent on deterrence	Suppress to incentivize reconsideration of precedent.	Deterrence is achieved through police conduct adjusting to precedent; suppression is unnecessary.	Deterrence value is insufficient to justify suppression here.
Scope of the good-faith exception for unsettled Fourth Amendment questions	Good-faith should encourage challenging settled precedents.	Good-faith should not chill challenge to precedent; limited in scope.	Good-faith exception applies; does not churn unsettled questions into suppressions.
Impact on development of Fourth Amendment law	Excluding would promote overruling precedent and deter ossification.	Law development proceeds via certiorari and overruling; exclusion is a remedy tool, not a policy changer.	Exclusion remains limited; binding-precedent reliance does not trigger suppression.

Chimel v. California, 395 U.S. 752 (U.S. Supreme Court, 1969) (initial aircraft of automobile-search guidance for arrests)
New York v. Belton, 453 U.S. 454 (U.S. Supreme Court, 1981) (bright-line rule permitting vehicle search incident to arrest)
Arizona v. Gant, 556 U.S. 332 (U.S. Supreme Court, 2009) (overruled Belton’s broad rule when occupants are not reachable)
Herring v. United States, 555 U.S. 135 (U.S. Supreme Court, 2009) (good-faith exception limited by culpability and deterrence)
United States v. Leon, 468 U.S. 897 (U.S. Supreme Court, 1984) (good-faith reliance on a technically invalid warrant)
Krull v. United States, 480 U.S. 340 (U.S. Supreme Court, 1987) (extension of good-faith to reasonable reliance on invalid statutes)
Evans v. United States, 514 U.S. 1 (U.S. Supreme Court, 1995) (good-faith reliance on erroneous information in a database)
Griffith v. Kentucky, 479 U.S. 314 (U.S. Supreme Court, 1987) (retroactivity standard for new rules of criminal procedure)
Linkletter v. Walker, 381 U.S. 618 (U.S. Supreme Court, 1965) (retroactivity framework later abandoned in Griffith)
Davis v. United States (Arizona v. Gant context), 556 U.S. 332 (U.S. Supreme Court, 2009) (overruled Belton for certain arrest scenarios)