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Massachusetts v. Sheppard

The Court Applies The Good Faith Rule

The Supreme Court created the "good faith" rule in United States v. Leon. The rule states that evidence gathered in violation of the Fourth Amendment's guarantee against unreasonable search and seizure will still be admissible in a trial if the police acted reasonably, although mistakenly. The good faith exception was deemed necessary because the exclusionary rule was designed to prevent police misconduct. Suppressing evidence gathered without police misconduct occurring would not serve the purpose of the exclusionary rule and would benefit criminals.

The Supreme Court agreed to hear Massachusetts v. Sheppard to determine if the officers reasonably believed that the search of Sheppard's residence was authorized by a valid warrant. The trial court and the majority of the Massachusetts Supreme Court felt that there was an objectively reasonable basis for the officers' mistaken belief that the warrant authorized the search they conducted. The majority of the Supreme Court justices agreed with these lower courts.

The attorney for Sheppard argued that since O'Malley knew the warrant form was defective he should have examined it to see if the necessary changes had been made.

Justice White wrote the opinion for the majority stating, "The officers in this case took every step that could reasonably be expected of them . . . We refuse to rule that an officer is required to disbelieve a judge who has just advised him, by word and by action, that the warrant he possesses authorizes him to conduct the search . . . " White pointed out that in most jurisdictions, the determinations of a judge are valid and binding, even if erroneous, until they are set aside through recognized procedure. White noted that there is little reason why an officer "should be expected to disregard assurances that everything is all right especially when he has alerted the judge to the potential problems."

White summed up by noting that the police conduct in this case was objectively reasonable. The judge, not the police officers, made the mistake. Since the exclusionary rule was designed to deter unlawful searches by police, not to punish clerical errors by judges, suppressing the evidence would not serve a deterrent purpose. The decision of the Supreme Judicial Court was reversed and the case sent back for further proceedings.

Justices Brennan and Marshall dissented in this case, stating that under the Fourth Amendment, illegally obtained evidence cannot be admitted. Their dissent in this case appeared in United States v. Leon. There they stated that the main deterrent function of the exclusionary rule goes beyond just the prevention of police misconduct. They felt that if a search warrant was defective for any reason, including an honest mistake, the evidence in the case should be suppressed. Brennan and Marshall stated that this strict interpretation would preserve the integrity of law enforcement and the Fourth Amendment. They summed up their dissent by noting that the majority's viewpoint "robbed the [exclusionary] rule of legitimacy."

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1981 to 1988Massachusetts v. Sheppard - Significance, The Court Applies The Good Faith Rule, Excluded Evidence Can Still Be Used In Court