United States v. Calandra

United States v. Calandra was the most important exclusionary rule case decided in the 1970s. The concept of the rule being a deterrent to police misconduct and the idea of weighing the costs of the rule against its benefits formed the basis of judicial thinking on the matter. The ruling in United States v. Calandra reflected the views of President Richard Nixon's appointee, Chief Justice Burger, who had serious reservations about the usefulness of the exclusionary rule.

In the 1980s the Supreme Court created even larger exceptions to the exclusionary rule, severely limiting its application. In United States v. Leon (1984) the Court created the "good faith" exception, stating that if officers acted in good faith, the evidence they unlawfully gathered would still be admissible in court. In the Leon case, the opinion quoted United States v. Calandra, stating that using the fruits of a past unlawful search or seizure "works no new Fourth Amendment wrong." In 1995, the Supreme Court revisited the good faith exception in Arizona v. Evans and used the same quotation from Calandra. In Evans, the Court decided that evidence gathered illegally due to a clerk's error need not be excluded.

The exclusionary rule has many critics. Some have criticized the Court for limiting the rule by creating the good faith exception. Others have suggested that the rule be abolished because it hinders law enforcement. Members of Congress have proposed legislation to do away with the rule in federal court, but such legislation has not yet been adopted.