2
Syllabus
state-court decision rests upon an adequate and independent state ground was adopted (1) to obviate the unsatisfactory and intrusive practice of requiring state courts to clarify their decisions to this Court's satisfaction and (2) to provide state judges with a clearer opportunity to develop state jurisprudence unimpeded by federal interference and yet preserve the federal law's integrity. Michigan properly serves its purpose and should not be disturbed. State courts are free both to interpret state constitutional provisions to accord greater protection to individual rights than do similar provisions of the United States Constitution and to serve as experimental laboratories. However, in cases where they interpret the United States Constitution, they are not free from the final authority of this Court. In this case, the State Supreme Court based its decision squarely upon its interpretation of federal law when it discussed the appropriateness of applying the exclusionary rule, and it offered no plain statement that its references to federal law were being used only for the purpose of guidance and did not compel the result reached. Pp. 6-10. 2. The exclusionary rule does not require suppression of evidence seized in violation of the Fourth Amendment where the erroneous information resulted from clerical errors of court employees. The exclusionary rule is a judicially created remedy designed to safeguard against future violations of Fourth Amendment rights through its deterrent effect. However, the issue of exclusion is separate from whether the Amendment has been violated. The Amendment does not expressly preclude the use of evidence obtained in violation of its commands, and exclusion is appropriate only where the rule's remedial objectives are thought most efficaciously served. The same framework that this Court used in United States v. Leon, 468 U. S. 897, to determine that there was no sound reason to apply the exclusionary rule as a means of deterring misconduct on the part of judicial officers responsible for issuing search warrants applies in this case. The exclusionary rule was historically designed as a means of deterring police misconduct, not mistakes by court employees. See id., at 916. In addition, respondent offers no evidence that court employees are inclined to ignore or subvert the Fourth Amendment or that lawlessness among these actors requires application of the extreme sanction of exclusion. See ibid. In fact, the Justice Court Clerk testified that this type of error occurred only once every three or four years. Finally, there is no basis for believing that application of the exclusionary rule will have a significant effect on court employees responsible for informing the police that a warrant has been quashed. Since they are not adjuncts to the law enforcement team engaged in ferreting out crime, they have no stake in the outcome of particular prosecutions. Application of the exclusionary rule also could not
Page: Index Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: October 4, 2007