946 F.3d 1239
11th Cir.2020Background
- Jeffery Hill, a federal prisoner on supervised release, was arrested after a routine traffic stop for possession of marijuana, possession of a firearm by a prohibited person, and possession of drug paraphernalia.
- Hill moved to suppress the evidence seized during the stop, arguing the detention, search, and seizure violated the Fourth Amendment.
- The district court denied suppression, concluding the exclusionary rule does not apply to supervised-release revocation proceedings.
- Hill appealed the denial of the suppression motion; he argued the evidence should be suppressed but did not directly press that the exclusionary rule should apply to revocation proceedings.
- The Eleventh Circuit reviewed factual findings for clear error and legal conclusions de novo and affirmed, relying on Supreme Court precedent refusing to extend the exclusionary rule beyond criminal trials and on circuit authority holding the rule inapplicable to supervised-release revocations.
- The court emphasized the Supreme Court’s rationale in parole contexts (substantial social costs, limited deterrent effect) and noted Hill offered no reason to diverge from that precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the exclusionary rule applies so evidence seized in an allegedly unlawful stop must be suppressed in supervised-release revocation proceedings | Hill: Evidence from the stop should be suppressed because detention/search/seizure violated the Fourth Amendment | Government/District Court: Exclusionary rule does not extend to supervised-release revocation proceedings; suppression not required | The court held the exclusionary rule does not apply to supervised-release revocation proceedings and affirmed denial of suppression |
Key Cases Cited
- Arizona v. Evans, 514 U.S. 1 (1995) (discusses limits of exclusionary rule and exceptions)
- Herring v. United States, 555 U.S. 135 (2009) (explains purpose and scope of exclusionary rule)
- Pa. Bd. of Prob. & Parole v. Scott, 524 U.S. 357 (1998) (refuses to extend exclusionary rule to parole revocation proceedings)
- I.N.S. v. Lopez-Mendoza, 468 U.S. 1032 (1984) (exclusionary rule not applied to deportation proceedings)
- United States v. Janis, 428 U.S. 433 (1976) (declines to extend exclusionary rule to civil proceedings)
- United States v. Calandra, 414 U.S. 338 (1974) (exclusionary rule does not apply to grand jury proceedings)
- United States v. Phillips, 914 F.3d 557 (7th Cir. 2019) (circuit holding exclusionary rule inapplicable to supervised-release revocation hearings)
- United States v. Charles, 531 F.3d 637 (8th Cir. 2008) (same)
- United States v. Hebert, 201 F.3d 1103 (9th Cir. 2000) (same)
- United States v. Armstrong, 187 F.3d 392 (4th Cir. 1999) (same)
- United States v. Montez, 952 F.2d 854 (5th Cir. 1992) (same)
- United States v. Lewis, 674 F.3d 1298 (11th Cir. 2012) (standard of review for suppression motions)