United States v. Peltier

Background

A man driving a 1962 Chevrolet was stopped by roving Border Patrol agents about 70 air miles from the Mexican border. Agents found three bags containing 270 pounds of marihuana in his trunk. He was indicted for possessing and intending to distribute the drugs. At trial his motion to suppress the seized evidence was denied, he stipulated to possession, and was convicted. On appeal the Ninth Circuit reversed, applying this Court’s earlier decision in Almeida-Sanchez to similar pending cases and ordering the evidence suppressed.

Reasoning

The Supreme Court considered whether the exclusionary rule — which bars use of evidence obtained in unconstitutional searches — had to be applied to searches done before the Almeida-Sanchez decision. The Government conceded the search would be unconstitutional under Almeida-Sanchez, but argued the exclusionary rule should not be mechanically applied to earlier searches. The Court emphasized that Border Patrol agents acted under a federal statute (8 U.S.C. §1357(a)(3)), a regulation setting a 100-air-mile enforcement zone, and prior judicial approvals. Because officers reasonably relied on longstanding statutory, regulatory, and judicial practice, the Court held the exclusionary rule did not require suppressing this evidence.

Real world impact

The decision lets prosecutors use evidence from roving Border Patrol vehicle searches done before Almeida-Sanchez when agents acted in reasonable reliance on the statute, regulation, and prior court decisions. It narrows when a new Fourth Amendment ruling will wipe out convictions based on earlier searches, affecting many immigration and drug prosecutions near the border.

Dissents or concurrances

Several Justices dissented, arguing Almeida-Sanchez reaffirmed traditional Fourth Amendment limits and that the exclusionary rule should bar use of unconstitutionally seized evidence even in pre-decision cases.