Illinois v. Krull (1986)

Docket
85-608
Decided
1986-01-01

Summary

Question: Does the good faith exception to the exclusionary evidence rule apply when a police officer relied on a statute that was later held unconstitutional? Conclusion: Yes. In a 5-4 decision, Justice Harry A. Blackmun wrote the majority opinion reversing and remanding. The Supreme Court held that the exclusionary rule does not apply because the officer acted in good faith. The officer’s reliance on the unconstitutional law was objectively reasonable when he conducted the search. Excluding the evidence in this case would not support the policy behind the exclusionary rule to deter police misconduct. The Court followed United States v. Leon 468 U.S. 897 (1984) where police conducted a search with a warrant that they later found out was defective. Justice Sandra Day O’Connor wrote a dissent, stating that United States v. Leon qs distinguishable from this case. She also asserted that the rule the majority adopted was inconsistent and difficult to apply. Justices William J. Brennan and John Paul Stevens joined in the dissent. Justice Thurgood Marshall wrote a dissent, joining in Justice O’Connor’s dissent, but expressing that her discussion of prior precedent was unnecessary.

View the full interactive analysis on SCOTUS Lens →