Davis v. United States

Background

On an April evening in 2007, officers in Greenville, Alabama, stopped a car, arrested the driver, Stella Owens, and the passenger, Willie Davis. The officers handcuffed both, placed them in separate patrol cars, and searched the vehicle’s passenger compartment. They found a revolver in the passenger’s jacket pocket. Davis was later charged under federal law for possessing a firearm as a convicted felon. At the time, the Eleventh Circuit had binding precedent that permitted the search, so the officers followed circuit law.

Reasoning

The Court addressed whether evidence should be suppressed when police conduct a search in objective, reasonable reliance on binding appellate precedent that is later overruled. The majority explained that the exclusionary rule is a judge-made remedy aimed at deterring bad police behavior, not at punishing officers who followed controlling law. Because the officers here acted in strict compliance with binding circuit precedent and were not culpable, suppression would not advance deterrence and would impose heavy social costs. The Court therefore held that searches made in objectively reasonable reliance on binding appellate precedent are not subject to the exclusionary rule.

Real world impact

The ruling means that when police follow clear, controlling decisions from an appeals court, evidence they obtain generally will not be thrown out later if the Supreme Court or another court changes the law. Convictions based on such evidence can be affirmed, even when a later decision says the search would now be unconstitutional. The decision leaves open different rules where precedent was unsettled or nonbinding.

Dissents or concurrances

Justice Sotomayor agreed with the judgment but stressed the decision does not resolve searches where law is unsettled. Justice Breyer (joined by Justice Ginsburg) dissented, warning the new exception undermines remedies and could weaken Fourth Amendment protection.