Willie Gene Davis v. United States (SCOTUS 2011)

Summary

The Supreme Court held that evidence obtained through a search conducted in objectively reasonable reliance on binding appellate precedent is not subject to the exclusionary rule, because suppression would yield no appreciable deterrence of culpable police conduct while imposing heavy costs on truth and public safety. The Court rejected the argument that this good-faith ruling conflicts with retroactivity doctrine, reasoning that retroactive application of a new constitutional rule and the availability of a suppression remedy are analytically distinct, so Arizona v. Gant applies to Davis's still-pending direct appeal even though suppression is unwarranted. It also rejected the contention that the ruling will ossify Fourth Amendment law, noting remaining avenues for challenging precedent and reserving a possible one-time exception for the litigant who wins the overruling decision. The Eleventh Circuit's judgment was affirmed. Justice Breyer, joined by Justice Ginsburg, dissented, arguing the new exception is incompatible with Griffith and threatens to swallow the exclusionary rule; Justice Sotomayor concurred in the judgment on narrower appreciable-deterrence grounds while reserving the unsettled-law question.

Holding

Whether the exclusionary rule applies to evidence obtained in a search conducted in objectively reasonable reliance on binding appellate precedent later overruled.. No. Searches conducted in objectively reasonable reliance on binding appellate precedent are not subject to the exclusionary rule.

Whether applying the good-faith exception to reliance on overruled precedent conflicts with the Court's retroactivity jurisprudence or revives the discarded case-by-case retroactivity regime.. No. Retroactive application of a new constitutional rule and the choice of remedy are distinct doctrines. Because Davis' conviction was not final on direct review when the new rule was announced, the new rule applies retroactively and Davis may invoke it, but exclusion does not automatically follow from a Fourth Amendment violation; the good-faith exception is an established limit on the remedy no different in kind from inevitable discovery.

Whether a good-faith exception for reliance on binding precedent will stunt the development of Fourth Amendment law by removing the incentive to challenge precedent.. No. Applying the exception will not prevent judicial reconsideration of prior Fourth Amendment precedents: defendants in jurisdictions where the question remains open retain undiminished incentive to litigate, counsel commonly test precedent by arguing it is distinguishable, and the Court can grant certiorari. In a future case the Court could recognize a limited exception allowing the defendant who obtains a judgment overruling precedent to receive suppression.

Summary

Holding

Cited authorities