480 U.S. 340 (1987)
In 1981 the Illinois Vehicle Code required persons or firms licensed to sell motor vehicles or deal in used parts, including operators of automobile wrecking yards, to maintain detailed records of all purchases and sales that included identification numbers and dates of acquisition and disposition.1 The same provision directed licensees to permit state and local police officers to inspect those records and the vehicles and parts on the business premises at any reasonable time during the night or day.2 Respondents Krull, Lucas, and Mucerino operated Action Iron & Metal, Inc., an automobile wrecking yard located in Chicago.3
On the morning of July 5, 1981, Chicago Police Detective Leilan K. McNally entered the yard, identified himself as a police officer, and asked to see the license and records of vehicle purchases.4 Lucas, who was working at the yard that day, could not locate the license or complete records but produced a paper pad listing approximately five vehicle purchases.5 McNally then requested and received permission to examine vehicles on the lot.6 Using a mobile computer, he checked the serial numbers of several vehicles and determined that three had been reported stolen and that the identification number on a fourth had been removed.7
McNally seized the four vehicles and placed Lucas under arrest at the scene.8 Respondent Krull, the holder of the license, and respondent Mucerino, who had been present at the yard on the day of the search, were arrested later.9 Respondents were charged with criminal violations of the Illinois motor vehicle statutes.10
The Circuit Court of Cook County granted respondents' motion to suppress the seized evidence after concluding that the inspection statute was unconstitutional.11 The Illinois Supreme Court affirmed that ruling.12 The State of Illinois petitioned for a writ of certiorari, which the United States Supreme Court granted.13
Whether the Fourth Amendment exclusionary rule applies to evidence obtained by police officers who acted in objectively reasonable reliance on a statute authorizing warrantless administrative searches when that statute is subsequently declared unconstitutional?14
The good-faith exception to the exclusionary rule recognized in United States v. Leon applies when police officers act in objectively reasonable reliance on a statute authorizing warrantless administrative searches that is later declared unconstitutional.15 The exclusionary rule deters police misconduct rather than punishing errors of legislators, who are presumed to act constitutionally and are not adjuncts to law enforcement; absent evidence that legislatures enact invalid statutes to subvert the Fourth Amendment, suppression would have little deterrent effect on officers sworn to enforce statutes as written.16
Yes. The good-faith exception recognized in Leon applies because Detective McNally entered respondents' licensed wrecking yard on July 5, 1981, identified himself, requested records under the Illinois Vehicle Code provision then in effect for over two years, and upon Lucas producing a partial pad listing five purchases, obtained permission to examine vehicles and used a mobile computer to identify three as stolen.17 The statute directed licensees to permit inspections of records and premises at any reasonable time, and McNally had no reason to believe it was facially invalid or grossly unconstitutional.18 Because the rule targets police rather than legislative error, and McNally fulfilled his duty to enforce the statute as written, exclusion would not advance deterrence.19
The evidence seized from respondents' junkyard need not be excluded under the Fourth Amendment because the good-faith exception applies.20
Related opinions on this issue
Justice O’Connor dissented on the ground that Leon's rationale does not extend here because the statute removed the neutral magistrate entirely and gave officers unfettered discretion, unlike a warrant issued by a judicial officer.21 She emphasized that the Fourth Amendment's core concern was legislative authorization of unreasonable searches, as shown by the writs of assistance.22 History supplies evidence that legislatures can threaten Fourth Amendment values.23
Applying the exclusionary rule would deter such enactments, whereas the majority's grace period creates a positive incentive for unconstitutional statutes.24 She further noted that the rule adopted is difficult to administer.25 Courts must determine when a statute becomes clearly unconstitutional under evolving law.26
The approach is anomalous under Griffith v. Kentucky because the defendant who successfully challenges the statute receives no remedy.27