In June 2011, the U.S. Supreme Court affirmed the conviction of a man whose constitutional rights were violated. The decision chipped away at court precedent protecting defendant’s Fourth Amendment rights.
In April 2007, Willie Davis was convicted of the weapons crime possessing a firearm as a felon. Davis was arrested for providing a false name to police officers during a routine traffic stop. While he sat in the back of a patrol car, officers searched the vehicle in which Davis had been a passenger and found a handgun in his jacket pocket.
The Law Regarding Searches of Cars
In 2009, the U.S. Supreme Court held in Arizona v. Gant that officers cannot search a vehicle as part of a “search incident to arrest” unless 1) the person being arrested is within reaching distance of that vehicle during the search, or 2) the arresting officers believe the vehicle contains evidence of the crime for which the person is being arrested.
Gant distinguished the Court’s prior holding in New York v. Belton (1981), which allowed the search of a vehicle’s passenger compartment around the same time of the arrest of an occupant of that vehicle.
The officers in Davis’ case acted in accordance with Belton, which was the law of the land in 2007. With the High Court’s subsequent Gant decision, Davis appealed his conviction asserting that his Fourth Amendment rights had been violated. He argued that because the gun was unconstitutionally discovered, it should have been suppressed under the “exclusionary rule.” The exclusionary rule generally precludes the use of evidence obtained in violation of constitutional principles and rights.
The Erosion of the Exclusionary Rule
The Supreme Court agreed that under Gant, the search in Davis’ case was unconstitutional. However, seven of the nine Justices ruled that despite the exclusionary rule, suppression of the evidence was not required, due to the “good faith” exception to the exclusionary rule’s application.
In his opinion, Justice Alito said that while the exclusionary rule’s purpose is to deter improper police conduct, the officers in Davis’ case acted in good faith under Gant so suppression of the handgun evidence would not serve as any deterrent to police misconduct. Therefore, Davis’ conviction was affirmed.
Though not nullifying the exclusionary rule, the Court significantly limited its application. There is no set measurement or definition of what constitutes good faith when evaluating the exclusionary rule. Instead, courts have reviewed all of the circumstances surrounding each individual case. The court’s expansive view of good faith in Davis’ case dilutes Fourth Amendment protections and privacy rights for everyone.
Constitutional protections are the backbone of our criminal justice system. A criminal defense lawyer who will fight to protect your rights is crucial.